Court filing
Original Complaint — Kevin Lofton v. Small Business Administration (C.D. Cal. 2022)
Filed November 4, 2022 in Lofton v. SBA; one of 2 filings from this case.
Record facts
| Court | UNITED STATES DISTRICT COURT FOR |
|---|---|
| Filed | 2022-11-04 |
UNITED STATES DISTRICT COURT FOR · No. 2:22-cv-07334-SPG-AS · Doc. 9 · 2022-11-04 · Docket on CourtListener
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Kevin Lofton
868Victor Ave #14
Inglewood, CA, 90302
(310) 773-1296
UNITED STATES DISTRICT COURT FOR
THE CENTRAL DISTRICT OF CALIFORNIA
KEVIN LOFTON,
Plaintiff,
vs.
ISABELLA GUZMAN,
ADMINISTRATOR SMALL
BUSINESS ADMINISTRATION,
Defendant(s)
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Case No. 2:22-cv-07334-SPG-ASx
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ORIGINAL COMPLAINT FOR DAMAGES UNDER THE
FEDERAL TORT CLAIMS ACT
1. This is an action brought pursuant to the Federal Tort Claims Act,
(“FTCA”) and the Fourth and Fifth Amendments to the United States
Constitution, 28 U.S.C. §1331, §1346(b), §1402(b), §2401(b), and §§2671-
11-4-2022
PG
Case 2:22-cv-07334-SPG-AS Document 9 Filed 11/04/22 Page 1 of 32 Page ID #:56
FILED
CLERK, U.S. DISTRICT COURT
CENTRAL DISTRICT OF CALIFORNIA
BY: ___________________ DEPUTY
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2680, by Kevin Lofton against the Small Business Administration
(SBA) for civil penalties for violating the Privacy Act, 5 U.S.C. § 552a,
for violating Title VI 42 U.S.C. § 2000d et seq., regarding retaliation
and discrimination, for violating the Takings Clause of the US
Constitution, U.S. Const. amend. V, and for the intentional infliction of
emotional distress 18 U.S. Code § 2340, for knowingly and willfully
trading private information and government documents related to
Plaintiff Kevin Lofton without Plaintiffs permission or authorization for
non-law enforcement purposes, for discriminating against Plaintiff in
the application of a business loan, and for participating in an action to
take funds belonging to Plaintiff in an effort to intimidate and inflict
emotional distress.
JURISDICTION AND VENUE
2. This Court has jurisdiction pursuant to 28 U.S. Code § 1346
3. Venue is proper pursuant to 28 U.S. Code § 1346 and 28 U.S. Code
§§§§§ 6226, 6228(a), 7426, 7428, and7429
PARTIES
4. Plaintiff Kevin Lofton is a protected class citizen and accountant
by trade and the business owner of Skip 2 My Loop Publishing (and
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including Giant Comix), which had an insured business value of
$1,000,000 per Biberk Business Insurance Policy N9PL592338
5. Defendant is Isabella Guzman, Administrator of the US Small
Business Administration (SBA)
STATUTORY BACKGROUND
6. Under the Privacy Act, 5 U.S.C. § 552a, Federal agencies may not
disclose information without consent unless certain exceptions apply
to the disclosure. The following are the twelve (12) Privacy Act
Exemptions when consent to release information is not required:
1) to those officers and employees of the agency which
maintains the record who have a need for the record in the
performance of their duties;
2) required under section 552 of this title (FOIA disclosures);
3) for a routine use as defined in subsection (a)(7) of this section
and described under subsection (e)(4)(D) of this section
(routine uses);
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4) to the Bureau of the Census for purposes of planning or
carrying out a census or survey or related activity pursuant
to the provisions of title 13;
5) to a recipient who has provided the agency with advance
adequate written assurance that the record will be used
solely as a statistical research or reporting record, and the
record is to be transferred in a form that is not individually
identifiable;
6) to the National Archives and Records Administration as a
record which has sufficient historical or other value to
warrant its continued preservation by the United States
Government, or for evaluation by the Archivist of the United
States or the designee of the Archivist to determine whether
the record has such value;
7) to another agency or to an instrumentality of any
governmental jurisdiction within or under the control of the
United States for a civil or criminal law enforcement activity
if the activity is authorized by law, and if the head of the
agency or instrumentality has made a written request to the
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agency which maintains the record specifying the particular
portion desired and the law enforcement activity for which
the record is sought;
8) to a person pursuant to a showing of compelling
circumstances affecting the health or safety of an individual
if upon such disclosure notification is transmitted to the last
known address of such individual;
9) to either House of Congress, or, to the extent of matter
within its jurisdiction, any committee or subcommittee
thereof, any joint committee of Congress or subcommittee of
any such joint committee;
10) to the Comptroller General, or any of his authorized
representatives, in the course of the performance of the
duties of the Government Accountability Office;
11) pursuant to the order of a court of competent jurisdiction; or
12) to a consumer reporting agency in accordance with section
3711(e) of title 31. (5 U.S.C. § 552a)
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7. Title VI, 42 U.S.C. § 2000d et seq., was enacted as part of the
landmark Civil Rights Act of 1964. It prohibits discrimination on the
basis of race, color, and national origin in programs and activities
receiving federal financial assistance.
8. U.S. Const. amend. IV states, in relevant parts, that “the right of
the people to be secure in their persons, houses, papers, and effects,
against unreasonable searches and seizures, shall not be violated, and
no Warrants shall issue, but upon probable cause, supported by Oath of
affirmation, and particularly describing the place to be searched, and
the persons or things to be seized.
9. U.S. Const. amend. V creates a number of rights relevant to both
criminal and civil legal proceedings. In civil legal proceedings it
requires that “due process of law” be part of any proceeding that denies
a citizen “life, liberty or property” and requires the government to
compensate citizens when it takes private property for public use.
10. 18 U.S. Code § 2340 prohibits torture committed by public
officials under color of law against persons within the public official's
custody or control. Torture is defined to include acts specifically
intended to inflict severe physical or mental pain or suffering.
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11. 28 U.S.C. §1346(b), §1402(b), §2401(b), and §§2671-2680 provides
a limited waiver of the United States’ immunity from suit, allowing
claims “for damages for injury or loss of property, or personal injury or
death caused by the negligent or wrongful act or omission of any
employee of the Government while acting within the scope of his office
or employment, under circumstances where the United States, if a
private person, would be liable to the claimant in accordance with the
law of the place where the act or omission occurred.” 28 U.S.C. § 1346(b)
CLAIM FOR VIOLATION OF THE PRIVACY ACT
12. Early in the morning on Thursday, March 26, 2020, the Senate
passed the Coronavirus Aid, Relief, and Economic Security Act (the
“CARES Act”). On Friday, March 27, 2020, the House of
Representatives also passed the CARES Act and President Trump
quickly signed it into law the same day.
13. Title I of the CARES Act was separately titled the Keep
American Workers Paid and Employed Act. Perhaps the most impactful
provision of the Act was the availability of Small Business Association
(“SBA”) loans that may, under certain circumstances, have been
converted into grants. The goal of the Act was to provide capital to
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otherwise underfunded businesses, including non-profit organizations,
in an attempt to help those businesses retain employees on payroll,
covered by healthcare insurance, and off of unemployment.
14. Economic Injury Disaster Loans (“EIDL”) provided loans of up to
$2 million with interest rates capped at 3.75% for companies and 2.75%
for nonprofit organizations, with payment of principal and interest
deferred for up to 4 years. These loans were permitted to be used to pay
for expenses that could have been met had the disaster not occurred,
including payroll and other operating expenses.
15. In addition, a business that received an EIDL [ during the
covered period ] as a result of a coronavirus related disaster declaration
was eligible to apply for a Paycheck Protection Program (“PPP”) Loan or
the business may have refinanced their EIDL into a PPP Loan.
16. Section 1110 of the CARES Act also loosened credit standards for
borrowers eligible to apply for PPP Loans. For instance, the SBA may
have approved PPP Loans based solely on the applicant’s credit score,
without requiring submission of tax returns, or used alternative
appropriate methods of determining ability to repay.
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17. To obtain a loan via COVID EIDL, small business owners must
have met the eligibility requirements. Additionally, below were the credit
score requirements:
o $500,000 or under: 570
o Greater than $500,000: 625
Applicants were required to submit a signed and dated IRS Form 4506-T
for COVID EIDL authorizing the Internal Revenue Service (“IRS”) to
release business tax transcripts for SBA to verify their revenue.
18. As provided by Sec. 1102 (G) of the Cares Act, an eligible
recipient applying for a covered loan shall make a good faith
certification—
(I.) that the uncertainty of current economic conditions
makes necessary the loan request to support the ongoing
operations of the eligible recipient;
(II.) acknowledging that funds will be used to retain
workers and maintain payroll or make mortgage payments,
lease payments, and utility payments;
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(III.) that the eligible recipient does not have an application
pending for a loan under this subsection for the same purpose
and duplicative of amounts applied for or received under a
covered loan; and
(IV.) during the [ covered period ], that the eligible recipient
has not received amounts under this subsection for the same
purpose and duplicative of amounts applied for or received
under a covered loan.
19. Beginning March 17, 2021, Isabella Guzman was the
Administrator of the Small Business Administration
20. On or about September 1, 2021, Plaintiff submitted SBA loan
application # 3323639082 through the SBA Covid-19 EIDL portal for an
SBA EIDL loan in the amount of $195,000. Plaintiff has operated his
business since July 2014 and been a federally registered vendor through
SAMS since August 13, 2015. Plaintiff has published novels through
this business, registered a copyright through the US Copyright Office (
Registration Number TXu-1-952-138) and has developed intellectual
property including the country’s first “comic book universe of all black
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female superheroes”. At the time of operation, Plaintiff’s business had
less than 50 employees in addition to himself.
21. On or about September 15, 2021 SBA staff including and with the
participation of Administrator Guzman shared SBA loan application
#3323639082 with unauthorized federal agents and agencies including
US Treasury Office of Inspector General Special Agent-in-Charge Rod
Ammari, Director of Field Operations Office of IRS Criminal
Investigations Ryan Korner, Federal Deposit Insurance Corporation
(“FDIC”) Office of the Inspector General Special Agent-in-Charge
Jeffrey Pittano, (former) US Attorney for the Central District Tracy
Wilkison, and unidentified staff members of the White House, not for a
civil or criminal law enforcement purpose and not for any civil or
criminal law enforcement investigative purpose, but for the purpose of
identifying ways to harm Plaintiff’s economic interests. SBA staff and
contacted parties knew and or should have known that there was no
civil or criminal lawful basis to share Plaintiff’s loan application and
that there had been no allegations of any criminal activity alleged
against Plaintiff warranting criminal investigative review.
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22. Plaintiff alleges that SBA staff at the direction of and with the
knowledge of, Administrator Guzman, shared Plaintiff’s SBA loan
application to unauthorized parties in violation of the Privacy Act, in
order to give the illusion to necessary entities including Bank of
America and the Franchise Tax Board, that parties were conducting a
PPP criminal loan investigation, when in reality no such investigation
was being performed or lawfully conducted. Furthermore, Plaintiff
seeks to demonstrate and prove that the sharing of Plaintiff’s SBA loan
application through emails, texts, and phone conversations, was done
solely for the purpose of “freezing” Plaintiff’s loan application in order
that the application not be processed to deny Plaintiff proper review
and any allocation of a qualifiable EIDL.
23. On July 5, 2022 Plaintiff received a communication entitled
“EIDL Reconsideration Request SBA: 0011720007729” from SBA
Disaster and Recovery Specialist “Angela P.”, Office of Capital Access,
wherein the SBA admitted to sharing Plaintiff’s loan application with
an unnamed individual in the White House. Although Plaintiff is an
admirer and supporter of the President, Plaintiff never communicated
to any member of the White House about SBA loan application
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#3323639082 and never authorized the SBA to communicate any
information to the White House.
24. On July 5, 2022 Plaintiff also learned through the same
communication stated above, that SBA loan application #3323639082
had been denied on March 28, 2022 and that further appeals would not
be allowable as SBA funds had been finally exhausted on May 6, 2022.
25. Plaintiff aims to demonstrate that SBA loan application
#3323639082 was accessed numerous times by numerous individuals
and unauthorized individuals between September 2021 and May 5
2022, and SBA staff, at the direction of and with the knowledge of
Administrator Guzman, frequently allowed access to SBA loan
application #3323639082 wherein numerous notations and changes
were made to the application without including proper or any
attribution by any SBA staff member or officer in order to shield SBA
staff from any liability or exposure relating to the unauthorized access.
The manner in which SBA loan application #3323639082 was
improperly shopped around to government agencies and the
communications, both informal and formal, through texts, and emails,
from SBA officers including Administrator Guzman had the ultimate
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and desired effect of denying SBA loan application #332639082 for
$195,000 and denying the Plaintiff’s loan increase request to $495,000
without proper review or proper attribution.
CLAIM FOR VIOLATION OF TITLE VI
26. On or about April 6, 2021 Plaintiff began reporting to United
States Department of Justice (“DOJ”) officials including First Assistant
US Attorney for the Central District Stephanie Christensen, Assistant
US Attorney Christina Shay and (former) US Attorney for the Central
District Tracy Wilkison about significant false claims violations
committed by Plaintiff’s former employer UCLA and retaliatory
attempts made by UCLA staff, wherein UCLA staff had improper and
corrupt communications with a UCLA alumni and current Employment
Development Department (“EDD”) judge to create a public record
undermining Plaintiff’s credibility by characterization of being a
‘disgruntled employee’. As a result of the actions by UCLA and the EDD
judge, Plaintiff was issued an EDD judgment denying Plaintiff’s right to
EDD unemployment claims yet paradoxically Plaintiff was issued the
contested benefits, immediately after and in violation of the EDD
ruling. Although Plaintiff appealed the ruling and believed he was
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deserving of his unemployment benefits, Plaintiff realized he was being
issued the benefits in contravention of the EDD ruling in order to deny
Plaintiff standing in any suit and to protect EDD from future liability.
Nevertheless, Plaintiff reported the misallocation of government
resources immediately to both EDD and to the DOJ and informed DOJ
that while Plaintiff had contested the decision to deny the benefits,
Plaintiff had reason to believe the benefits were being issued to him in
order to rob him of standing in any future litigation against EDD.
Rather than investigate Plaintiff’s significant false claims allegations
against UCLA which were clearly outlined in a document generated by
Plaintiff entitled “UCLA violations”, and instead of investigating the
nature of Plaintiff being awarded benefits that EDD judges had ruled
against providing, DOJ instead began a months long campaign to warn
UCLA and EDD about any possible liability or exposure from Plaintiff,
and DOJ officials also began a months long campaign to use DOJ’s vast
powers and influence to discover any information about Plaintiff that
could be used against Plaintiff to prevent Plaintiff from pursuing claims
against UCLA or EDD.
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27. On or about April 12, 2021 and on or about May 5, 2021, Plaintiff
applied for and received a First Draw PPP loan for $11,836 and a
Second Draw PPP loan for $11,836, respectively, through third party
PPP lender, Womply Fast Lane, for combined loan amount totaling
$23,672. On or about June 15 2021 both the First Draw loan and
Second Draw loan were totally forgiven. For several months, from April
through September, DOJ and SBA had every opportunity to investigate
Plaintiff and pursue any justifiable charges or allegations of unlawful
activity against Plaintiff including for any possible indications that
Plaintiff had made false representations or filed false documents to any
state or federal agency. During this time DOJ and SBA through
exhaustive investigation were able to fully vet and clear Plaintiff of any
allegations of wrongdoing by Plaintiff and subsequently had
opportunity to verify Plaintiff’s allegations against UCLA and EDD by
launching an investigation into Plaintiff’s allegations. Though DOJ (and
SBA) used their powers to investigate and verify Plaintiff, no
investigations were launched into either UCLA or EDD despite
Plaintiff’s very specific reporting of allegations of waste, fraud, and
abuse. In short, DOJ (and affiliated federal agencies including SBA)
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were only concerned with using the powers of their agencies to discredit
Plaintiff, and not to pursue credible and easily verifiable allegations of
criminal conduct by UCLA officials and EDD officials.
28. On or about September 15, 2021 at the direction of Administrator
Guzman and SBA Office of the Inspector General Special Agent-in-
Charge Weston King, at the direction and suggestion of DOJ officials
including Tracy WIlkison, SBA staff effectively put a review hold on
SBA loan application #3323639082 in order that SBA loan application
#3323639082 would not be processed in the same manner as other SBA
loan applications and not be processed in accordance with the
provisions of the congressionally approved CARES Act and SBA EIDL
program.
29. Starting in September 2021, the SBA began and continued an
unrelenting campaign against Plaintiff whereby Plaintiff’s SBA loan
application was withheld from proper review and proper determination.
Furthermore, from September – March, Plaintiff’s loan application was
frequently accessed by SBA staff and non SBA staff, including by staff
of US Treasury Office of Inspector General Special Agent-in-Charge Rod
Ammari, Director of Field Operations Office of IRS Criminal
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Investigations Ryan Korner, FDIC Office of the Inspector General
Special Agent-in-Charge Jeffrey Pittano, and (former) US Attorney for
the Central District Tracy Wilkison, in which SBA loan application
#3323639082 was discussed through emails, texts and phone messages
by the same parties, and in which notations were frequently added
without any attribution to the agents accessing the application or
making changes to the application. Plaintiff regularly inquired of the
SBA about the status of this application and received many false
promises and assurances on the phone and in more than 50 emails from
SBA Disaster Customer Service and SBA PDC Reconsideration, that
the SBA would review and escalate the application to receive proper
determination. Such false promises had the effect of not only denying
Plaintiff proper consideration of his application, but also jeopardizing
Plaintiff’s business relationships as Plaintiff’s faith and credibility were
ruined by SBA’s deliberate mishandling and misleading tactics.
30. On December 31, 2021, due to the continued lag in processing
SBA loan application #3323639082, and due to the ongoing economic
relief needed to facilitate Plaintiff’s affected business operations,
Plaintiff applied for an EIDL targeted advance. Due to the fact Plaintiff
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is a minority and Plaintiff’s business is at least 51% minority owned,
and due to the fact that Plaintiff’s business is in a qualifying
economically disadvantaged area, Plaintiff qualified for and was
granted an EIDL targeted advance grant for $10,000 and $5,000.
31. Plaintiff alleges that the SBA was aware that Plaintiff was a
citizen of protected class due to the review and application process for
Plaintiff’s First Draw PPP loan, Second Draw PPP loan and the EIDL
targeted advance. Furthermore, SBA staff including Administrator
Guzman either knew or should have known that Plaintiff would be
qualified for and approved for an EIDL given the due diligence and
application review required to process Plaintiff’s First and Second Draw
loan and EIDL targeted advance.
32. Despite being evaluated for and having qualified for and having
been approved for the First and Second Draw PPP loans, as well as the
EIDL targeted advance, neither Administrator Guzman or any other
SBA official made any effort to determine Plaintiff’s eligibility for SBA
loan application #3323639082 during the 6-8 months the application
was put on hold, precisely because Administrator Guzman knew that
Plaintiff did qualify and should have been approved, and the SBA,
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FDIC, IRS DOJ and US Treasury were determined to not approve
Plaintiff’s SBA loan application #3323639082 . Regarding eligibility the
SBA did not attempt to verify Plaintiff’s credit score for loan eligibility,
nor did the SBA seek to review IRS form 4506-T strictly for loan
eligibility, rather the SBA sought Plaintiff’s tax history and tax
information not pertaining to years pertinent to the loan application in
an effort to find and leverage any outstanding taxes owed to the IRS
against Plaintiff so as to cause emotional distress.
33. Additionally, due to the procrastinated processing of SBA loan
application #3323639082 and due to the ongoing financial pressures of
distressed business operations, on December 31, 2021, Plaintiff
submitted an increase request to the SBA, sent to
covideidlincreaserequest@sba.gov for an increase to a new loan amount
of $495,000.
34. On June 5, 2022 Plaintiff was informed by the SBA that Plaintiff
was no longer eligible for an SBA loan because funding had been
exhausted in May 2022. Ultimately as a result of these tactics and false
promises and improper handling of Plaintiff’s loan application,
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Plaintiff’s business fell into an economic spiral that was irreparable,
causing the total loss of Plaintiff’s business, Skip 2 My Loop Publishing.
CLAIM FOR VIOLATION OF THE FOURTH AND THE TAKINGS
CLAUSE OF THE FIFTH AMENDMENT
35. On or about October 15, 2022, SBA Office of the Inspector
General Special Agent-in-Charge Weston King participated in
discussions with various federal agents and agencies including US
Treasury Office of Inspector General Special Agent-in-Charge Rod
Ammari, Director of Field Operations Office of IRS Criminal
Investigations Ryan Korner, FDIC Office of the Inspector General
Special Agent-in-Charge Jeffrey Pittano, and ( former ) US Attorney for
the Central District Tracy Wilkison to extend retaliatory efforts against
Plaintiff to include targeting Plaintiff’s personal banking account and
banking relationships by contacting Plaintiff’s banker, Bank of
America, in the guise of conducting a PPP loan investigation.
36. On October 28, 2021, at the direction of Special Agent-in-Charge
King and various federal agencies, including in emails, texts, and phone
calls between US Treasury Office of Inspector General Special Agent-in-
Charge Rod Ammari, Director of Field Operations Office of IRS
Case 2:22-cv-07334-SPG-AS Document 9 Filed 11/04/22 Page 21 of 32 Page ID #:76
Summary of Pleading - 22
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Criminal Investigations Ryan Korner, FDIC Office of the Inspector
General Special Agent-in-Charge Jeffrey Pittano, and ( former ) US
Attorney for the Central District Tracy Wilkison, Bank of America acted
to zero out Plaintiff’s personal bank account and business account of all
funds, including disaster relief funds allocated by order of the governor
of California, and funds designated to pay Plaintiff’s business expenses
and business insurance, and Plaintiff’s living and rent expenses, and
thereby remit those funds on instruction from agents including Special
Agent-in-Charge King to a third-party entity affiliate of the federal
government. Plaintiff’s funds were remitted under the guise of tax
collection, not reclaiming either the First or Second Draw loans which
had been totally forgiven and Plaintiff was not given any notice that the
government or any federal agency intended to take such action although
by law, Plaintiff was entitled to notification about tax disputes as well
as the opportunity to pay installment plans and or make any other
necessary arrangements to appeal or settle such claims in a timely
manner, in good faith, and on structured terms that would have not
been harmful to the Plaintiff or Plaintiff’s ultimate ability to pay any
and all outstanding taxes. Parties’ participation in the absconding of
Case 2:22-cv-07334-SPG-AS Document 9 Filed 11/04/22 Page 22 of 32 Page ID #:77
Summary of Pleading - 23
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Plaintiff’s personal and business funds robbed Plaintiff of the ability to
pay needed expenses including rent, utilities and business insurance
and was done solely for the purpose of devastating Plaintiff financially.
CLAIM FOR INTENTIONAL INFLICTION OF EMOTIONAL
DISTRESS
37. On February 17, 2022 SBA Office of the Inspector General
Special Agent-in-Charge Weston King personally received a request
from Plaintiff to review misconduct of SBA staff regarding the
discriminatory targeting and unlawfully sharing of SBA loan
application #3323639082 as well as address and take corrective actions
regarding the absconding of Plaintiff’s banking funds.
38. On or about February 17, 2021, Special Agent-in-Charge King
directed and or gave SBA staff including Administrator Guzman
permission to continue SBA staff misconduct and indicated that the
SBA Inspector General’s office would neither take corrective action with
respect to SBA misconduct nor investigate or prosecute SBA staff for
misconduct related to SBA loan application #3323639082.
Case 2:22-cv-07334-SPG-AS Document 9 Filed 11/04/22 Page 23 of 32 Page ID #:78
Summary of Pleading - 24
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39. Pursuant to the Federal Tort Claims Act, 28 U.S.C. §1346(b),
§1402(b), §2401(b), and §§2671-2680, Plaintiff filed standard form 95 on
July 31, 2022 through certified mail.
40. Since on or about February 17, 2022 the SBA Office of the
General Counsel has been read into and had knowledge of Plaintiff’s
claims and allegations and has since that time investigated and had
ample opportunity to investigate all allegations fully and performed all
due diligence to make proper lawful determinations for the SBA with
respect to Plaintiff’s claims. Furthermore, the SBA Office of the General
Counsel has long since determined and decided since on or about
February 17 2022 that no further investigation or determination need
be taken or performed or would be taken or performed by the SBA in
preparation of Plaintiff’s expected filing of claims. Subsequently,
Standard form 95 was received by the SBA on or about August 22, 2022
and was denied on or about August 23, 2022.
Case 2:22-cv-07334-SPG-AS Document 9 Filed 11/04/22 Page 24 of 32 Page ID #:79
Summary of Pleading - 25
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PRAYER FOR RELIEF
WHEREFORE, Plaintiff Kevin Lofton prays that this Court issue a
decision and order:
1.) Assessing a civil penalty of $1,000,000 for loss of
Plaintiff’s going concern Skip 2 My Loop Publishing Inc,,
plus $195,000 for the taking and impairment of SBA loan
application #3323639082 (not including loan increase
request amount of $495,00), plus $195,000 for actual
damages relating to violation of the Privacy Act (not
including loan increase request amount of $495,000), plus
$2,500 for actual damages related to the taking of
personal funds from Plaintiff’s personal bank account and
business bank account, and plus $102,500 for the
intentional infliction of emotional distress for a total sum
of damages of $1,495,000.
2.) Granting Plaintiff such further relief as the Court deems
just and proper.
Case 2:22-cv-07334-SPG-AS Document 9 Filed 11/04/22 Page 25 of 32 Page ID #:80
Summary of Pleading - 26
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Dated: October 6, 2022
Respectfully
submitted,
By,
[s] Kevin Lofton
Kevin Lofton, Pro Se
868 Victor Ave #14
Inglewood, CA, 90302
(310) 773-1296
Acting Pro Per
Case 2:22-cv-07334-SPG-AS Document 9 Filed 11/04/22 Page 26 of 32 Page ID #:81
July 31, 2022
Via Priority Mail with Delivery Confirmation
Office of the General Counsel
Small Business Administration
409 3rd Street, SW.,
Washington, DC 20416
Re: Demand for Payment
To whom it may concern
Please be advised that this is a demand for payment from the Small Business Administration, in
accordance with the Federal Torts Claims Act, for the sum of $1,495,000 for violations of the Privacy
Act, for violations of Title VI, regarding retaliation and discrimination, for violations of the Takings
Clause of the Fifth Amendment of the US Constitution, and for the intentional infliction of emotional
distress. On or about September 1, 2021, I submitted an application to the SBA for an economic disaster
injury loan in the amount of $195,000. This loan application was my property which I submitted to the
SBA for evaluation in consideration of approving a $195,000 loan from the SBA that my business
qualified for as a matter of law, in accordance with the emergency aid granted by Congress in order to
help small businesses such as mine which had suffered during the Covid pandemic. At the same time that
my EIDL loan application was submitted to the SBA, I was also engaged in a burgeoning legal dispute
with my former employer, the UC Regents/ UCLA Corporate Financial Services, regarding retaliation
and qui tam claims, presented by myself against the UC, for violations of the California and Federal False
Claims Act.
Due to the serious and sensitive nature of these qui tam and retaliation claims, I reported all allegations to
the US Department of Justice, directly to US Attorney Tracy L. Wilkison. Unbeknownst to myself at the
time, UCLA was preparing to enter into a new financial relationship involving the licensing and
agreement of a grant of rights agreement which UCLA hoped would net UCLA and additional annual
revenue gain of up to $100 million dollars, which could have been threatened or forfeited with the
revelations contained in my false claims whistleblower reports. In an effort to help preserve UCLA’s
financial ambitions, and as a political favor done to avoid embarrassing the UC and the UC’s interests and
political backers and beneficiaries, Ms Wilkison used her investigative powers to receive and review and
obstruct and arrest and ultimately “take” my SBA EIDL application (SBA loan application #3323639082)
Case 2:22-cv-07334-SPG-AS Document 9 Filed 11/04/22 Page 27 of 32 Page ID #:82
in such a way so as to prevent this application from being fairly evaluated per my request and per the
intent of the EIDL program.
Agents of the SBA facilitated and participated in the action of taking my SBA loan application. Agents of
the SBA, including SBA administrator Isabella Guzman and regional inspector general Weston King, had
knowledge of and or participated directly in the action of taking SBA loan application #3323639082 and
distributing this application to federal agencies other than the SBA. Agents of the SBA including SBA
administrator Isabella Guzman and regional inspector general Weston King, had knowledge of and/ or
participated in disseminating SBA loan application #3323639082 to the following federal agencies
including the Treasury department, FDIC, the IRS, and USDOJ. Additionally, the involvement of
Inspector General King lent a false air of propriety to this misconduct, while also indicating to the
offending agencies that the SBA Inspector General would lend his office to help protect the offenders
from retribution or prosecution.
Disseminating SBA loan application #3323639082 to agencies other than the SBA is a violation of the
Privacy Act. Per the Privacy Act, agencies may not disclose records between one another without a
person's written consent, except for law enforcement purposes. The SBA did not receive or request
written permission from me to share this application, nor was this application shared for law enforcement
purposes, but rather this application was shared and impeded in order to help another federal agency
retaliate against me for reporting false claims violations against the UC. Because SBA loan
application #3323639082 was singled out and denied fair consideration equal to every other application,
the SBA violated the Takings Clause of the Fifth Amendment, prohibiting the government from taking
private property without notification and compensation, and also the SBA, in doing so, willingly
participated in a broader effort to inflict intentional emotional distress upon myself and my business by
impairing my ability to secure economic injury disaster assistance for my business in violation with the
stated intent of Congress to help small businesses such as mine with such appropriation funding.
Additionally, agents of the SBA took active steps to also share my personal banking information as well
as tax information to agents of the FDIC (including FDIC Inspector General Jeff Pittano), US Treasury
(including special agent Rod Ammari), IRS (including special agent Ryan Korner), and USDOJ
(including US attorney Tracy Wilkison, US Assistant Attorney General Kenneth Polite, and Deputy
Assistant Attorney General/ Controller Jolene Lauria), in order to aid in efforts to inflict emotional
distress upon myself in an effort to retaliate against me for threatening the business and personal political
relationships enjoyed by the UC Regents/ UCLA. Sharing this banking and tax information was also a
violation of the Privacy Act, since it was done without written permission by me and was not done in a
law enforcement capacity, and was done with the aim and intention of targeting me and my business
interests and for the purposes of inflicting emotional distress.
The SBA’s conduct with respect to obstructing and taking SBA loan application #3323639082 was
outrageous and no reasonable person would find such conduct tolerable. Taking SBA loan
application #3323639082 and participating in efforts to target my interests utilizing my personal banking
information and tax information, not in a law enforcement capacity, is conduct so substantial or enduring
that no reasonable person could be expected to endure it As a result of these injuries, I have lost my
business and my bank accounts were debited without my permission, and payment was sent to the
government, without my permission, in such a way so as to prevent me from being able to pay my
Case 2:22-cv-07334-SPG-AS Document 9 Filed 11/04/22 Page 28 of 32 Page ID #:83
monthly living expenses, including my rent and also to prevent me from being able to sustain business
operations, including making timely payments of my business insurance.
Furthermore, Inspector General King’s involvement and review of these actions without issuing clear
guidance to SBA agents with respect to issues and areas of potential or actual agency wrongdoing, while
also not validating any assertions or conclusions that SBA agency actions were proper law enforcement
activities, lent the clear and unmistakable impression to the agency and agents that these actions were not
proper law enforcement activities and that agents need not fear punishment from the Inspector General’s
Office. Inspector General King’s actions and failure to demand that corrective actions be taken to address
agency wrongdoing in this regard made him complicit in these actions and led agents to understand that
the Inspector General’s Office would protect offending agents from punishment/ prosecution for these
violations.
Under the FTCA, 28 U.S.C. §§ 2671-2680, individuals who are injured or whose property is damaged by
the wrongful or negligent act of a federal employee acting within his or her official duties may file a
claim with the government for reimbursement for that injury or damage. To state a valid claim, the
claimant must demonstrate that:
1. he or she was injured, or his or her property was damaged by a federal government employee;
2. the employee was acting within the scope of his or her official duties;
3. the employee was acting negligently or wrongfully; and
4. the negligent or wrongful act proximately caused the injury or damage of which he or she
complains.
In an effort to resolve and release all future claims against the SBA for these actions, I file this claim and
am willing to except $1,495,000 in damages.
The sum is determined as follows:
$1,000,000 for loss of Skip 2 My Loop Publishing. This is the value of the company which was fully
insured and damaged and destroyed as a result of the SBA’s negligent and wrongful refusal to process
SBA loan application #3323639082. SBA’s misconduct with respect to the SBA’s failure to process SBA
loan application #3323639082 was negligent and wrongful, if not egregious, and resulted in such a way
that prevented me from reapplying for the EIDL or any other. SBA negligently and or wrongfully held on
to this loan without making a proper determination and as a result I could not apply for any other loan
before the funding eligibility window closed. Although SBA received and processed thousands of loan
applications after SBA loan application #3323639082 was submitted, the SBA withheld loan application
#3323639082 and negligently and or wrongfully discriminated against this application by not processing
or evaluating the loan application fairly and equally. The SBA’s actions and participation in the damage
to SBA loan application #3323639082 was negligent and wrongful.
.
$195,000 for the taking and impairment of SBA loan application #3323639082 for actual damages
relating to the violation of the Takings Clause of the Fifth Amendment. This is the value of SBA loan
application #3323639082. SBA’s actions and participation in the violation of the Takings Clause of the
Case 2:22-cv-07334-SPG-AS Document 9 Filed 11/04/22 Page 29 of 32 Page ID #:84
Fifth Amendment was wrongful and or negligent causing SBA loan application #3323639082 to be
shared amongst federal agencies without my permission, resulting in the actual monetary loss of $195,000
in qualifiable federal loans.
$195,000 for actual damages relating to violation of the Privacy Act with respect to the sharing of
SBA loan application #3323639082. SBA’s actions and participation in the violation of the Privacy Act
was wrongful and or negligent causing SBA loan application #3323639082 to be shared amongst federal
agencies without my permission, resulting in the actual monetary loss of $195,000 in qualifiable federal
loans.
$2,500 for actual damages relating to the taking of personal funds from my personal bank account
and business bank account. SBA’s actions and participation in this action was negligent and or
wrongful, causing the taking of funds/ damage to my personal and business bank account.
$102,500 for the intentional infliction of emotional distress. SBA’s conduct with respect to the above
was negligent and wrongful causing predictable, if not, intentional, infliction of emotional distress.
Total claim for damages $1,495,000 = $1,000,000 + $195,000 + 195,000 + $2,500, + $102,500
Sincerely
Kevin M. Lofton
868 Victor Ave #14
Inglewood CA, 90302
(Telephone: (310) 773-1296)
kevinmichaellofton@gmail.com
Case 2:22-cv-07334-SPG-AS Document 9 Filed 11/04/22 Page 30 of 32 Page ID #:85
INSTRUCTIONS: Please read carefully the instructions on the
reverse side and supply information requested on both sides of this
form. Use additional sheet(s) if necessary. See reverse side for
additional instructions.
FORM APPROVED
OMB NO. 1105-0008
1. Submit to Appropriate Federal Agency:
2. Name, address of claimant, and claimant's personal representative if any.
(See instructions on reverse). Number, Street, City, State and Zip code.
3. TYPE OF EMPLOYMENT
MILITARY
CIVILIAN
4. DATE OF BIRTH
5. MARITAL STATUS
6. DATE AND DAY OF ACCIDENT
7. TIME (A.M. OR P.M.)
8. BASIS OF CLAIM (State in detail the known facts and circumstances attending the damage, injury, or death, identifying persons and property involved, the place of occurrence and
the cause thereof. Use additional pages if necessary).
9.
PROPERTY DAMAGE
NAME AND ADDRESS OF OWNER, IF OTHER THAN CLAIMANT (Number, Street, City, State, and Zip Code).
BRIEFLY DESCRIBE THE PROPERTY, NATURE AND EXTENT OF THE DAMAGE AND THE LOCATION OF WHERE THE PROPERTY MAY BE INSPECTED.
(See instructions on reverse side).
10.
PERSONAL INJURY/WRONGFUL DEATH
STATE THE NATURE AND EXTENT OF EACH INJURY OR CAUSE OF DEATH, WHICH FORMS THE BASIS OF THE CLAIM. IF OTHER THAN CLAIMANT, STATE THE NAME
OF THE INJURED PERSON OR DECEDENT.
11.
WITNESSES
NAME
ADDRESS (Number, Street, City, State, and Zip Code)
12. (See instructions on reverse).
AMOUNT OF CLAIM (in dollars)
12a. PROPERTY DAMAGE
12b. PERSONAL INJURY
12c. WRONGFUL DEATH
12d. TOTAL (Failure to specify may cause
forfeiture of your rights).
I CERTIFY THAT THE AMOUNT OF CLAIM COVERS ONLY DAMAGES AND INJURIES CAUSED BY THE INCIDENT ABOVE AND AGREE TO ACCEPT SAID AMOUNT IN
FULL SATISFACTION AND FINAL SETTLEMENT OF THIS CLAIM.
13a. SIGNATURE OF CLAIMANT (See instructions on reverse side).
13b. PHONE NUMBER OF PERSON SIGNING FORM
14. DATE OF SIGNATURE
CIVIL PENALTY FOR PRESENTING
FRAUDULENT CLAIM
The claimant is liable to the United States Government for a civil penalty of not less than
$5,000 and not more than $10,000, plus 3 times the amount of damages sustained
by the Government. (See 31 U.S.C. 3729).
CRIMINAL PENALTY FOR PRESENTING FRAUDULENT
CLAIM OR MAKING FALSE STATEMENTS
Fine, imprisonment, or both. (See 18 U.S.C. 287, 1001.)
95-109
NSN 7540-00-634-4046
STANDARD FORM 95 (REV. 2/2007)
PRESCRIBED BY DEPT. OF JUSTICE
28 CFR 14.2
CLAIM FOR DAMAGE,
INJURY, OR DEATH
Authorized for Local Reproduction
Previous Edition is not Usable
Case 2:22-cv-07334-SPG-AS Document 9 Filed 11/04/22 Page 31 of 32 Page ID #:86
INSURANCE COVERAGE
In order that subrogation claims may be adjudicated, it is essential that the claimant provide the following information regarding the insurance coverage of the vehicle or property.
15. Do you carry accident Insurance?
Yes
Yes
If yes, give name and address of insurance company (Number, Street, City, State, and Zip Code) and policy number.
No
No
16. Have you filed a claim with your insurance carrier in this instance, and if so, is it full coverage or deductible?
17. If deductible, state amount.
18. If a claim has been filed with your carrier, what action has your insurer taken or proposed to take with reference to your claim? (It is necessary that you ascertain these facts).
19. Do you carry public liability and property damage insurance?
Yes
If yes, give name and address of insurance carrier (Number, Street, City, State, and Zip Code).
No
INSTRUCTIONS
Claims presented under the Federal Tort Claims Act should be submitted directly to the "appropriate Federal agency" whose
employee(s) was involved in the incident. If the incident involves more than one claimant, each claimant should submit a separate
claim form.
Complete all items - Insert the word NONE where applicable.
A CLAIM SHALL BE DEEMED TO HAVE BEEN PRESENTED WHEN A FEDERAL
AGENCY RECEIVES FROM A CLAIMANT, HIS DULY AUTHORIZED AGENT, OR LEGAL
REPRESENTATIVE, AN EXECUTED STANDARD FORM 95 OR OTHER WRITTEN
NOTIFICATION OF AN INCIDENT, ACCOMPANIED BY A CLAIM FOR MONEY
DAMAGES IN A SUM CERTAIN FOR INJURY TO OR LOSS OF PROPERTY, PERSONAL
INJURY, OR DEATH ALLEGED TO HAVE OCCURRED BY REASON OF THE INCIDENT.
THE CLAIM MUST BE PRESENTED TO THE APPROPRIATE FEDERAL AGENCY WITHIN
TWO YEARS AFTER THE CLAIM ACCRUES.
Failure to completely execute this form or to supply the requested material within
two years from the date the claim accrued may render your claim invalid. A claim
is deemed presented when it is received by the appropriate agency, not when it is
mailed.
If instruction is needed in completing this form, the agency listed in item #1 on the reverse
side may be contacted. Complete regulations pertaining to claims asserted under the
Federal Tort Claims Act can be found in Title 28, Code of Federal Regulations, Part 14.
Many agencies have published supplementing regulations. If more than one agency is
involved, please state each agency.
The claim may be filled by a duly authorized agent or other legal representative, provided
evidence satisfactory to the Government is submitted with the claim establishing express
authority to act for the claimant. A claim presented by an agent or legal representative
must be presented in the name of the claimant. If the claim is signed by the agent or
legal representative, it must show the title or legal capacity of the person signing and be
accompanied by evidence of his/her authority to present a claim on behalf of the claimant
as agent, executor, administrator, parent, guardian or other representative.
If claimant intends to file for both personal injury and property damage, the amount for
each must be shown in item number 12 of this form.
The amount claimed should be substantiated by competent evidence as follows:
(a) In support of the claim for personal injury or death, the claimant should submit a
written report by the attending physician, showing the nature and extent of the injury, the
nature and extent of treatment, the degree of permanent disability, if any, the prognosis,
and the period of hospitalization, or incapacitation, attaching itemized bills for medical,
hospital, or burial expenses actually incurred.
(b) In support of claims for damage to property, which has been or can be economically
repaired, the claimant should submit at least two itemized signed statements or estimates
by reliable, disinterested concerns, or, if payment has been made, the itemized signed
receipts evidencing payment.
(c) In support of claims for damage to property which is not economically repairable, or if
the property is lost or destroyed, the claimant should submit statements as to the original
cost of the property, the date of purchase, and the value of the property, both before and
after the accident. Such statements should be by disinterested competent persons,
preferably reputable dealers or officials familiar with the type of property damaged, or by
two or more competitive bidders, and should be certified as being just and correct.
(d) Failure to specify a sum certain will render your claim invalid and may result in
forfeiture of your rights.
PRIVACY ACT NOTICE
This Notice is provided in accordance with the Privacy Act, 5 U.S.C. 552a(e)(3), and
concerns the information requested in the letter to which this Notice is attached.
A. Authority: The requested information is solicited pursuant to one or more of the
following: 5 U.S.C. 301, 28 U.S.C. 501 et seq., 28 U.S.C. 2671 et seq., 28 C.F.R.
Part 14.
B. Principal Purpose: The information requested is to be used in evaluating claims.
C. Routine Use: See the Notices of Systems of Records for the agency to whom you are
submitting this form for this information.
D. Effect of Failure to Respond: Disclosure is voluntary. However, failure to supply the
requested information or to execute the form may render your claim "invalid."
PAPERWORK REDUCTION ACT NOTICE
This notice is solely for the purpose of the Paperwork Reduction Act, 44 U.S.C. 3501. Public reporting burden for this collection of information is estimated to average 6 hours per
response, including the time for reviewing instructions, searching existing data sources, gathering and maintaining the data needed, and completing and reviewing the collection of
information. Send comments regarding this burden estimate or any other aspect of this collection of information, including suggestions for reducing this burden, to the Director, Torts
Branch, Attention: Paperwork Reduction Staff, Civil Division, U.S. Department of Justice, Washington, DC 20530 or to the Office of Management and Budget. Do not mail completed
form(s) to these addresses.
STANDARD FORM 95 REV. (2/2007) BACK
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