Court filing

U.S. Small Business Administration's Petition for Remission of Seized Property (Exhibit A) — United States v. $168,849.42 Seized from First Community Bank, et…

Filed June 23, 2026 in U.S. v. 168849 Seized First Community Bank; one of 12 filings from this case.

Record facts

Court	U.S. District Court, Southern District of West Virginia (Beckley)
Filed	2026-06-23

U.S. District Court, Southern District of West Virginia (Beckley) · No. 5:23-cv-00393 · Doc. 29-1 · 2026-06-23 · Docket on CourtListener

Full text

U.S. SMALL BUSINESS ADMINISTRATION
WASHINGTON, DC 20416
December 19, 2023
United States Attorney’s Office
ATTN: AUSA Christopher R. Arthur
Southern District of West Virginia
300 Virginia Street East, Suite 4000
Charleston, West Virginia 25301
RE:
Petition for Remission – SBA-DOJ2023-000066: United States v. $168,849.42 Seized from
First Community Bank, Account Number XX2781, et al.; Civil Case No. 5:23-cv-00393
Dear Sir/Madam,
Please find enclosed the Small Business Administration’s Petition for Remission together with
Exhibit “A” and Wiring Instructions. The SBA is a Cabinet Level Federal Agency and is charged
by Congress to administer Covid Relief funds. Your Agency has identified SBA as the victim of
fraud resulting in the seizures designated in your notice. SBA has carefully reviewed its records
and has matched your Agency’s seizure number with the SBA loan or grant and the amount of
money SBA has paid on the loan or grant to date. Enclosed is SBA’s certified petition which
proves that it is owed these funds. Please return the seized assets to SBA for the SBA to properly
account for the funds returned for each loan and/or grant as soon as possible. SBA must properly
account for the amounts collected for each loan or grant. SBA’s Wiring Instructions are included.
Also, please find enclosed with the Petition, SBA’s Exhibit B – Certified Statements of Account
(CSOAs) and Proof of Payment supporting SBA’s claim as the victim and providing the total
indebtedness for the PPP loan, EIDL loan, and EIDL grant advance in this matter.
Type
Loan No.
Principal
Forgiveness
Interest
Forgiveness
PPP Admin. Fee
Total Indebtedness
PPP
7702977206
$188,000.00
$1,653.37
$9,400.00
$199,053.37
Type
Loan No.
Loan Amount
Accrued
Interest*
Application
No.
Grant
Advance
Amount
Total
Indebtedness
EIDL
6296888002
$2,000,000.00
$148,017.11
as of 12/6/23
3306574670
$10,000.00
$2,158,017.11
*Interest is accruing at rate of 3.750% with a daily rate of $205.48 per day, as provided on the
corresponding CSOA.
EXHIBIT A
Case 5:23-cv-00393 Document 29-1 Filed 06/23/26 Page 1 of 29 PageID #: 128

Should you have any questions regarding SBA’s Petition for Remission, please email me at the
address below and “cc” Shantal Phillips at Shantal.Phillips@sba.gov.
Best Regards,
_______________________
Anthony Parham
Trial Attorney
U.S. Small Business Administration
Washington, DC
Enclosures
Petition for Remission
Exhibit A Table of loans and seizures
Exhibit B CSOAs & Proof of Payment
Exhibit C Wiring instructions
Case 5:23-cv-00393 Document 29-1 Filed 06/23/26 Page 2 of 29 PageID #: 129

U.S. SMALL BUSINESS ADMINISTRATION
WASHINGTON, DC 20416
IN RE SEIZED PROPERTY
U.S. SMALL BUSINESS ADMINISTRATION’S
PETITION FOR REMISSION OF SEIZED PROPERTY
The United States Small Business Administration files this petition for remission in
response to the notice from your Agency based upon your Agency’s investigation. The seized
funds must be returned to SBA as the victim of fraud as was determined by your Agency. SBA as
a Federal Agency is not required to execute a “hold harmless agreement.” In addition, SBA as a
Federal Agency should not be charged any fees by your Agency. All the funds should be returned
to SBA so that the funds can be properly accounted for against the loan/or grant. For each seizure
identified in Exhibit A, the SBA has searched its Federal Records and determined that the amount
seized is due to be returned to SBA. SBA requests that these funds be returned without any delay
and as soon as possible.
***********************************************************************
PLEASE SEE WIRING INSTRUCTIONS ATTACHED HERETO ON THE LAST
PAGE, EXHIBIT C, for transmitting funds to SBA. PLEASE provide the loan numbers
with the wire so that the funds can be properly accounted for. Please send Ms. Shantal
Phillips an email when the funds are transmitted. Shantal.Phillips@sba.gov
************************************************************************
Respectfully submitted,
Eric S. Benderson
Associate General Counsel for Litigation
___________________________
BY: Anthony Parham
Trial Attorney
U.S. Small Business Administration
Office of General Counsel
409 3rd Street, SW, Ste.7200

Washington, DC 20416
Anthony.Parham@sba.gov
Case 5:23-cv-00393 Document 29-1 Filed 06/23/26 Page 3 of 29 PageID #: 130

JURAT
Pursuant to 17 U.S. Code § 1746, I, Anthony Parham, an Attorney for the Small Business
Administration (the Agency), hereby certify that I have the authority to make this Certification
and that the official financial records of the U.S. Small Business Administration (SBA) have been
reviewed by SBA and each of the seizure(s) listed in Exhibit “A” contain funds which were
disbursed by the SBA in the amount shown for each seizure number for the corresponding Loan
and/or Grant.
Your Agency notified SBA that it is a victim of fraud based upon its investigation.
Consequently, all seized funds should be returned to SBA by sending the funds via the wiring
instructions included with this petition. It is essential for SBA to know for each seizure number
the amount awarded, the seizure number and the loan number for the seized funds to be properly
accounted for by SBA.
I attest and declare under penalty of perjury that the U.S. Small Business Administration’s
(SBA’s) claims to this property are not frivolous, and that the information contained in this
Certification and Exhibit “A” in support of the SBA’s claim(s) is true and correct.
Signed December 19, 2023
Anthony Parham
Trial Attorney
U.S. Small Business Administration
Office of General Counsel
409 3rd Street, SW, Ste.7200
Washington, DC 20416
Anthony.Parham@sba.gov
Case 5:23-cv-00393 Document 29-1 Filed 06/23/26 Page 4 of 29 PageID #: 131

Petition for Remission
Exhibit A
Dated: 12/19/2023

SEIZURE
NUMBER
SBA
FILE/LOAN
NUMBER
BANK ACCOUNT
NUMBER
SEIZURE
AMOUNT
SBA LOAN
AMOUNT
United States v.
$168,849.42 Seized
from First
Community Bank,
Account Number
XX2781, et al.;
Civil Case No.
5:23-cv-00393
First Community Bank /
8602781 (23-NAS-
000006)
$168,849.42
United States v.
$168,849.42 Seized
from First
Community Bank,
Account Number
XX2781, et al.;
Civil Case No.
5:23-cv-00393
First Community Bank /
9572600 (23-NAS-
000007)
$299,604.40
United States v.
$168,849.42 Seized
from First
Community Bank,
Account Number
XX2781, et al.;
Civil Case No.
5:23-cv-00393
Cash Frozen from Ally
Invest Securities, LLC
Account Number 643-
56295-11 RR A34 (23-
NAS-000008)
$2,333,832.28
United States v.
$168,849.42 Seized
from First
Community Bank,
Account Number
XX2781, et al.;
Civil Case No.
5:23-cv-00393
Securities Frozen from
Ally Invest Securities
LLC Account Number
643-56295-11-RR-A34
(23-NAS-000009)
$45,000.00

Case 5:23-cv-00393 Document 29-1 Filed 06/23/26 Page 5 of 29 PageID #: 132

Multiple lines per seizure number appear where multiple loans were deposited to the same account.
Claim is per loan number subject to seizure amount.

Case 5:23-cv-00393 Document 29-1 Filed 06/23/26 Page 6 of 29 PageID #: 133

Small Business Administration
SMALL BUSINESS ADMINISTRATION
Office of Performance, Planning, and the Chief Financial Officer
Program Accounting Division
Loan Accounting Branch
Denver, CO 80259
CERTIFIED STATEMENT OF ACCOUNT
As of 12/15/2023
Loan Number:
7702977206
Lender Name:
First Community Bank
Borrower Name:
R & R Delivery, Inc.
Borrower Address:
144 Arbor Lane
Cool Ridge, WV 25825 US
Total Amount Disbursed by Lender to Borrower:
Loan
$188,000.00
Less: Principal Payments
$0.00
Less: Principal Forgiveness
$188,000.00
Lender Principal Balance
$0.00
Total Amount Disbursed by SBA to Lender:
Principal Forgiveness
$188,000.00
Add: Interest Forgiveness
$1,653.37
Add: PPP Processing Fee
$9,400.00
SBA Charges Outstanding
$199,053.37
Total Indebtedness
$199,053.37
Last 1502 Report Date
Interest Paid Through
03/31/2021
03/22/2021
Certified to be a true and accurate statement as reflected by the official accounting records of the Small Business
Administration
12/15/2023
Vikki Matamoros, Lead Accountant
Authorized Signature and Title
Date
SBA FORM 596 B (8-81)
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Exhibit B
Case 5:23-cv-00393 Document 29-1 Filed 06/23/26 Page 7 of 29 PageID #: 134

Small Business Administration

SMALL BUSINESS ADMINISTRATION
Office of Performance, Planning, and the Chief Financial Officer
Program Accounting Division
Loan Accounting Branch
Denver, CO 80259
CERTIFIED STATEMENT OF ACCOUNT
As of 12/06/2023
(Interest accrued on unpaid balance through above date)

Loan Number:
6296888002
Borrower Name:
R & R Delivery, Inc.
Borrower Address:
144 Arbor Lane
COOL RIDGE, WV 25825-9488 US
Total Amount Disbursed:

Loan
$2,000,000.00

Care and Preservation of Collateral
$0.00

Recoverable Expenses
$0.00
Total Amount Disbursed
$2,000,000.00
Less: Repayments
$0.00
Current Balance
$2,000,000.00
Add: Accrued Interest
$148,017.11
Total Charges Outstanding
$2,148,017.11
Less: Escrow Balance
$0.00

Total Indebtedness
$2,148,017.11

Interest rate on loan is 3.750%. Interest calculated thru 12/06/2023 Daily interest rate is currently accruing at a rate of
$205.48 per day.
Date of Last Transaction
Interest Paid Through

11/16/2023
07/08/2020

Certified to be a true and accurate statement as reflected by the official accounting records of the Small Business
Administration

12/06/2023
Luma Jasim, Lead Accountant
Authorized Signature and Title
Date
SBA FORM 596 B (8-81)
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3 / 3
Case 5:23-cv-00393 Document 29-1 Filed 06/23/26 Page 8 of 29 PageID #: 135

Payee ID:
EIDG:3306574670\
TRACE
NUMBER:
06302020101036153380394
Payee
Name:
R & R Delivery,
Inc.
ALC:
73000001
Payment
Date:
06/30/2020
Payment
Amount:
$10,000.00
TAS:
07320202021 0500000
Schedule
Number:
000000SG062901
BETC:
DISB
Payment
Status:
PAYMENT HAS
BEEN
PROCESSED
Payee's FI
C/S DAN:
C 0009572660
FI RTN:
051501299
FI Name:
FIRST
COMMUNITY
BANK
FI Address:
P O BOX 989
ONE
COMMUNITY
PLACE
BLUEFIELD, VA
24605
FI Phone:
(304) 323-6300
Cancellation
Date:
Reason For
Return:
Orig
Return
Reason
Code:
Case 5:23-cv-00393 Document 29-1 Filed 06/23/26 Page 9 of 29 PageID #: 136

Exhibit C

IMPORTANT
**********************************************************

INSTRUCTIONS FOR REMITTING FUNDS TO SBA

For Payment of Restitution, Seized or Forfeited Funds:
 Ensure each payment is separated out when returning
 Remitting payment via IPAC is preferred
 Agency Location Code (ALC): 73000001
 Treasury Account Symbol (TAS): 073 F 3875 000
 Business Event Type Code (BETC): COLLBCA
 EIN/TIN: 53-0215587
 In the “miscellaneous” section, include the petition number, the forfeiture or seizure
number, or the loan or application number
For questions about IPAC transfers of funds, please contact Steve Frost at (303) 844-7992,
Steve.Frost@sba.gov or Michael Ordija at (630) 712-3653, Michael.Ordija@sba.gov.

Case 5:23-cv-00393 Document 29-1 Filed 06/23/26 Page 10 of 29 PageID #: 137

Case 5:23-cv-00393 Document 1
iled 05/17/23 Page 1 of 18 PagelD #: 1
UNITED STATE DISTRICT COURT
SOUTHERN DISTRI T CF WEST VIRGINIA
BE KLEY
UNITED STATES OF AMERICA,
Plaintiff
V.
$168,849.42 SEIZED FROM FIRST CO
$299,604.40 SEIZED FROM FIRST CO
$2,333,832.28 CASH FROZEN FROM ALLY
NUMBERXXX-X6295-11 RRA34;
$45,000.00 SECURITJES FROZEN FROM
NUMBERXXX-X6295-l 1 RRA34;
Defendants in rem.
Civil Action No.:
5:23-cv-393
TY BANK, ACCOUNT NUMBER XX:2781;
TY BANK, ACCOUNT NUMBER XX:2660;
VEST SECURITJES, LLC, ACCOUNT
Y INVEST SECURITJES, LLC, ACCOUNT
VERIFJED COMPLAINT OR FORFEITURE IN REM
COMES NOW, Plaintiff, United States f America (the "United States"), by and through
the undersigned Assistant United States Attome , and alleges as follows:
1.
This is a civil action for forfeitu
in rem, pw-suant to 18 U.S.C. § 981(a)(l)(A),
(1 )(C), the procedures set f01th in Rule G of the Supplemental Rules for Admiralty or Maritime
Case Clain1s and Asset Forfeitw-e Actions, the F deral Rules of Civil Procedure, and 18 U.S.C. §
985, to forfeit assets that theft of government
ds, theft of stolen funds across state lines, wire
fraud, and money laundering in violation of 18
.S.C. §§ 287, 641, 1343, 1956, and/or property
traceable to such property (the "Defendant Asse "). The Defendant Assets also are involved in
monetary transactions in violation of 18 U.S.
§ 1957, laundering of monetaty instruments
exceeding $10,000.
2.
The Defendant Assets, which inclu e 4 Defendant Accounts totaling approximately
$2,847,286.10 in value are more particularly desc ibed as:
1
Case 5:23-cv-00393 Document 29-1 Filed 06/23/26 Page 11 of 29 PageID #: 138

Case 5:23-cv-00393 Document 1 Fled 05/17/23 Page 2 of 18 PagelD #: 2
"Defendant Assets"
(i)
$168,849.42 seized from Fir t Community Bank account number XX:2781
("personal account 2781 ");
(ii)
$299,604.40 seized from First ommunity Bank account number XX:2660 ("R&R
account 2660");
(iii)
$2,333,832.28 cash frozen fro
Ally Invest Securities, LLC, account number
XXX-X6295-ll RR A34 ("Al
-X6295-11 "); and
(iv)
$45,000.00 securities frozen fr m Ally Invest Securities, LLC, account number
XXX-X6295-11 RR A34 ("Ally XX-X6295-l 1").
3.
This action seeks forfeiture of a 1 rights, title and interest in the above-captioned
Defendant Assets because the properties con itute or are derived from proceeds of theft of
government funds, theft of stolen funds across state lines, wire fraud, and money laundering in
violation of 18 U.S.C. §§ 287, 641, 1343, and 956. The Defendant Assets also are involved in
monetary transactions in violation of 18 U.S. . § I 9 5 7, laundering of monetary instruments
exceeding $10,000.
4.
In March 2020, in response to t e COVID-19 pandemic, Congress enacted the
Coronavirus Aid, Relief, and Economic Securit Act (the "CARES Act""). See (,"'A.RES ACT§
1102, 134 Stat. at 286 (codified as amended at 15 U.S.C. § 636(a)(36)). The CARES Act
authorized the Small Business Administration "SBA") to provide low-interest loans to small
businesses, also known as the Economic Injury
isaster Loan ("EIDL''). SBA's EIDL program
provides small businesses with working capital oans of up to $2 million to help overcome the
temporary loss of revenue.
II.
JURISDICT ON AND VENUE
2
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Case 5:23-cv-00393 Document 1 F led 05/17/23 Page 3 of 18 PagelD #: 3
5.
This Court has jurisdiction over e subject matter. See 28 U.S.C. §§ 1345, 1355(a).
6.
This Court has in rem jurisdict on over the Defendant Assets. See 28 U.S.C. §§
1345, 1355(a).
7.
The Defendant Assets have bee seized and are in the custody of the United States,
except Ally XXX-X6295-11 which is currently restrained by the United States.
8.
Venue for this action is proper i the Southern District of West Virginia because
acts or omissions giving rise to the forfeiture oc urred in this District. See 28 U.S.C. § 1355(b)(l).
III.
F ACTUA ALLEGATIONS
9.
Ross Bailey ("Bailey") obtained housands of dollars in proceeds in the Defendant
Assets, captioned above, and engaged in theft of ovemment proceeds, and engaged in transactions
in violation of the money laundering laws, inclu ng transactions that promoted his illicit activities,
namely his wire fraud. Bailey also used the ace unts to attempt to conceal the fraud.
10.
Bailey violated 18 U.S.C § 641 (t eftofgovemmentfunds), 18 U.S.C. § 1343 (wire
fraud), 18 U.S.C. § 666 (theft or bribery concern ng programs receiving Federal funds), 18 U.S.C.
§ 1956 (laundering of monetary instruments), nd 18 U.S.C. § 1957 (laundering in monetary
transactions in property derived from specified u lawful activity exceeding $10,000).
11.
Bailey resides within the Southe
District of West Virginia, Cool Ridge, Raleigh
County, West Virginia.
12.
Bailey is a 100% Shareholder, of &R Delivery Inc. ("R&R"), an S Corporation.
13.
R&R is a West Virginia corpora ion incorporated in 2005 at the West Virginia
Secretary of State's Office and the principal place of business is in Raleigh County, West Virginia,
which is in the Southern District of West Virgini .
THE ECONOMIC INJUR DISASTER LOAN PROGRAM
3
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Case 5:23-cv-00393 Document 1 Fled 05/17/23 Page 4 of 18 PagelD #: 4
14.
The Economic Injury Disaster oan Program ("EIDL") is a United States Small
Business Administration ("SBA") program that rovided low-interest financing to small businesses,
renters, and homeowners in regions affected by declared disasters.
15.
The CARES Act authorized the SBA to provide EID L loans of up to $2 million to
eligible small businesses experiencing subst ntial financial disruption due to the COVID-19
pandemic.
16.
To obtain an EIDL loan, a quali ing business is required to submit an application
to the SBA and to provide information about
e business's operations, such as the number of
employees, and revenues for the 12-month peri d preceding the disaster, and cost of goods sold in
the 12-month period preceding the disaster. I the case of EIDL loans for COVID-19 relief, the
12-month period was the 12-month period fr
January 31, 2019 to January 31 , 2020. The
applicant was also required to certify that the in rmation in the application was true and correct to
the best of the applicant's knowledge.
17.
EIDL loan applications were su mitted directly to the SBA and processed by the
agency with support from a government contract r. The amount of the loan, if the application was
approved, was determined based, in part, on t e information provided by the applicant about
employment, revenue, and cost of goods sold.
ny funds issued under an EIDL loan were issued
directly by the SBA
18.
EIDL loan funds could be used fi r payroll expenses, sick leave, production costs,
and business obligations, such as debts, rent, and ortgage payments. If the applicant also obtained
a loan under the PPP, the EIDL loan funds could ot be used for the same purpose as the PPP loan
funds.
Case 5:23-cv-00393 Document 29-1 Filed 06/23/26 Page 14 of 29 PageID #: 141

Case 5:23-cv-00393 Document 1 Fled 05/17/23 Page 5 of 18 PagelD #: 5
19.
SBA's Amended Loan Autho ization and Agreement includes the following
language regarding any potential civil and/or cri inal penalties:
Whoever wrongfully misapplies the p oceeds of an SBA disaster loan shall be
civilly liable to the Administrator in an
ount equal to one-and-one half times the
original principal amount of the loan un er 15 U.S.C. 636(b). In addition, any false
statement or misrepresentation to
BA may result in criminal, civil or
administrative sanctions including, but not limited to: 1) fines, imprisonment or
both, under 15 U.S.C. 645, 18 U.S.C. 1 01, 18 U.S.C. 1014, 18 U.S.C. 1040, 18
U.S.C. 3571, and any other applicable 1 ws; 2) treble damages and civil penalties
under the False Claims Act, 31 U.S.C. 3 29; 3) double damages and civil penalties
under the Program Fraud Civil Remedi s Act, 31 U.S.C. 3802; and 4) suspension
and/or debarment from all Federal procu ement and non-procurement transactions.
Statutory fines may increase if amende by the Federal Civil Penalties Inflation
Adjustment Act Improvements Act of2 15.
RELEVANT LENDING INSTI UTIONS
20.
Lender A and Bank 1 (First Co munity Bank) were financial institutions insured
by the Federal Deposit Insurance Company ("F IC") and Bank 1 was an approved SBA lender of
PPP loans.
21.
Lender B is the United States S
11 Business Administration.
BANK ACCOUNTS CONTROL ED BY ROSS BAILEY
22.
Bailey maintained the following bank accounts:
(a) named as authorized sig er on R&R account XX2660 in the name
ofR&R whose headquart rs is in Man, West Virginia;
(b) named as authorized sign r on personal account XX2 781;
( c) named as authorized sign r on personal account XX3 l 3 7;
( d) named as authorized sign r on personal brokerage account number
XXX-X6295-l l RR A34
aintained at Ally Invest Securities, LLC
whose headquarters is in harlotte, North Carolina.
( e) named as authorized sign on an account carried by APEX Clearing
whose headquarters is in allas, TX.
5
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Case 5:23-cv-00393 Document 1 Fled 05/17/23 Page 6 of 18 PagelD #: 6
FIRST EIDL LOA for $150 000.00
23.
On or about June 25, 2020, Bailey on behalf of R&R electronically
applied for an EIDL loan for $150,000.00 wit SBA. SBA approved the loan application.
24.
On or about July 8, 2020, the SB sent $150,000.00 in EIDL loan proceeds
via an ACH transfer to R&R account XX266 . On or about June 30, 2020, Bailey
electronically signed a Loan Authorization an Agreement. Bailey also signed the note
to the SBA as the owner of R&R and upload
the DocuSign Loan Document to SBA.
25.
Bailey represented in the Lo n Authorization and Agreement that he
would use the proceeds of the EIDL Loan sol ly as working capital to alleviate COVID
related economic injury.
26.
These EIDL loan proceeds
e not being considered as part of this
forfeiture action.
SECOND EIDL LOAN OF $ 50 000.00 First Modification
27.
On or about August 9, 2021,
ailey on behalf of R&R electronically
applied for an EIDL loan modification for $3 0,000.00 with SBA. SBA approved the
First Modification of the EIDL loan, incre ing the amount from $150,000.00 to
$500,000.00.
28.
On or about August 31, 2021, ailey electronically signed an Amended
Loan Authorization and Agreement. Bailey lso signed the note to the SBA as the
owner of R&R and uploaded the DocuSign
oan Document to SBA. On or about
6
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Case 5:23-cv-00393 Document 1 F led 05/17/23 Page 7 of 18 PagelD #: 7
September9,2021, the SBA sent $350,000.00 i EIDL loan proceeds viaanACHtransferto
R&R's account XX2660.
29.
Bailey represented in the Am nded Loan Authorization and Agreement
that he would use the proceeds of the EIDL oan solely as working capital to alleviate
COVID related economic injury.
30.
These EIDL loan proceeds re not being considered as part of this
forfeiture action.
THIRD EIDL LOAN OF $1 5 0 000.00 Second Modification
31 .
On or about February 22, 202 , Bailey on behalf of R&R electronically
applied for a second modification to the EID loan with the SBA, increasing the loan
amount by an additional $1,500,000.00.
3 2.
Bailey did not have to submit an
ditional EIDL Loan Application for 1he first or
second modification due to SBA applying the •
rmation contained in the initial EIDL Loan
ApplicatioIL
33.
SBA approved the Second M dification of the EIDL loan, increasing
the amount from $500,000.00 to $2,000,000.0
34.
On or about February 25,
022, Bailey electronically signed an
Amended Loan Authorization and Agreement or Application Number 3306574670.
35.
On or about February 25, 2022, t e SBA approved the requested EIDL loan
modification. The SBA Loan# is #629688800 .
7
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Case 5:23-cv-00393 Document 1 Fled 05/17/23 Page 8 of 18 PagelD #: 8
36.
Bailey signed the note to th SBA as the owner ofR&R and uploaded
the DocuSign Loan Document to SBA.
37.
OnoraboutMarchl,2022, SB sent$1,500,000.00inEIDL loan.proceeds
viaanACHtransfertoR&R account XX2660.
38.
Bailey represented in the Am nded Loan Authorization and Agreement
that he would use the proceeds of the EIDL oan solely as working capital to alleviate
economic mJury.
39.
Instead of using the EIDL
ds for permissible purposes, Bailey used
the EIDL funds to personally enrich himself y transferring these funds to his personal
bank accounts and/or to personal investment ccounts.
IMPROPER USE OF
40.
On or about 3/8/2022, Baile transferred $700,000.00 from the R&R
account• XX2660 to his personal account XX2 81.
41.
On or about 3/9/2022, Bailey ansferred $30,000.00 out of his personal
account XX2781 to Ally XXX-X6295-1 l.
42.
On or about 3/11/2022, Bailey ansferred $30,000.00 out of his personal
account XX2781 to Ally XXX-X6295-1 l.
43.
On or about 3/14/2022, Bailey
ferred $30,000.00 out of his personal
account XX2781 to Ally XXX-X6295-1 l.
44.
On or about 3/15/2022, Bailey ansferred $30,000.00 out of his personal
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account XX2781 to Ally XXX-X6295-1 l.
45.
On or about 3/17/2022, Baile transferred $30,000.00 out of his personal
account XX2781 to Ally :XXX-X6295-1 l.
46.
On or about 3/18/2022, Baile transferred $30,000.00 out of his personal
account XX2781 to Ally XXX-X6295-l l .
4 7.
On or about 3/23/2022, Baile transferred $30,000.00 out of his personal
account XX2781 to Ally XXX-X6295-1 l.
48.
On or about 3/24/2022, Baile transferred $30,000.00 out of his personal
account XX2781 to Ally XXX-X6295-l l.
49.
On or about 3/25/2022, Bailey transferred $30,000.00 out of his personal
account XX2781 to Ally XXX-X6295-1 l.
50.
On or about 3/29/2022, Bailey transferred $30,000.00 out of his personal
account XX2781 to Ally XXX-X6295-l 1.
51.
On or about 3/29/2022, Bailey wire transferred $700,000.00 out of R&R
account XX2660 to APEX Clearing.
52.
On or about 3/30/2022, Bailey ansferred $30,000.00 out of his personal
account XX2781 to Ally XXX-X6295-1 l.
53.
On or about 3/30/2022, Bailey uthorized APEX Clearing to wire transfer
$699,970.00 to R&R account XX2660.
54.
On or about 3/31/2022, Bailey
• e transferred $700,000.00 out of R&R
9
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Case 5:23-cv-00393 Document 1 Fil d 05/17/23 Page 10 of 18 PagelD #: 10
account XX2660 to APEX Clearing.
55.
On or about 4/1/2022, Bailey authorized APEX Clearing to wire transfer
$699,970.00 to R&R account XX2660.
56.
On or about 4/1/2022, Bailey ansferred $700,000.00 from R&R account
XX2660 to his personal account XX278 l.
57.
On or about 4/5/2022, Bailey ·re transferred $700,000.00 out his personal
account XX2781 to Apex Clearing.
58.
On or about 4/22/2022, Baile transferred $30,000.00 out of his personal
account XX2781 to Ally XXX-X6295.,1 l.
59.
On or about 4/27/2022, Bailey transferred $30,000.00 out of his personal
account XX2781 to Ally XXX-X6295-1 l.
60.
On or about 4/29/2022, Bailey transferred $30,000.00 out of his personal
account XX2781 to Ally XXX-X6295-1 l.
61.
On or about 5/6/2022, Bailey ansferred $30,000.00 out of his personal
account XX2781 to Ally XXX-X6295-1 l.
62.
On or about 5/10/2022, Bailey ansferred $30,000.00 out of his personal
account XX2781 to Ally XXX-X6295-1 l.
63.
On or about 5/13/2022, Bailey ansferred $30,000.00 out of his personal
account XX2781 to Ally XXX-X6295-1 l.
64.
On or about 5/18/2022, Bailey ansferred $30,000.00 out of his personal
1
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Case 5:23-cv-00393 Document 1 Fil d 05/17/23 Page 11 of 18 PagelD #: 11
account XX2781 to Ally XXX-X6295-1 l.
65.
On or about 5/19/2022, Baile transferred $30,000.00 out of his personal
account XX2781 to Ally XXX-X6295-1 l.
66.
On or about 5/24/2022, Baile transferred $30,000.00 out of his personal
account XX2781 to Ally XXX-X6295-l l.
67.
On or about 5/27/2022, Baile transferred $30,000.00 out of his personal
account, XX2781 to Ally XXX-X6295-11.
68.
On or about 5/31/2022, Baile transferred $30,000.00 out of his personal
account XX2781 to Ally XXX-X6295-l 1.
CONCEALMENT BY TRANSFERRIN FUNDS AT END OF TAX YEAR
69.
On or about 12/30/2022, Baile authorized APEX Clearing to wire transfer
$1,600,000.00 to his personal account XX2781.
70.
On or about 12/30/2022, Baile then transferred $1,600,000.00 out of his
personal account XX2781 to R&R account XX 660.
71.
On or about 01/06/2023, Bail y transferred $1 ,500,000.00 out of R&R
account XX2660 and back to his personal acco
t XX278 l.
72.
On or about 01/10/2023, Baile also transferred $600,000.00 out of R&R
account XX2660 to his personal account XX27 1.
73.
On or about 01/11/2023, Baile also transferred $200,000.00 out of R&R
account XX2660 to his personal account XX27
Case 5:23-cv-00393 Document 29-1 Filed 06/23/26 Page 21 of 29 PageID #: 148

Case 5:23-cv-00393 Document 1 Fil d 05/17/23 Page 12 of 18 PagelD #: 12
74.
On or about 01/11/2023, Bail y then transferred $2,000,000.00 out of his
personal account XX2781 to Apex Clearing.
IV.
R FORFEITURE
Count One-En
ctitious or :fraudulent claims
75.
The United States incorporates y reference paragraphs 1 through 74 above as if
fully set forth herein.
76.
Pursuant to 18 U.S.C. § 287, it s a federal crime to "make[] or present[] to any
person or . . . to any department or agency there f, any claim upon or against the United States, or
any department or agency thereof, any claim up nor against the United States, or any department
or agency thereof, knowing such claim to be fal e, fictitious, or fraudulent. . . "
77.
As set forth above, Bailey knowi gly made false, fictitious or fraudulent claims to
the United States, and the Defendant Asset were involved in transactions or attempted
transactions in violation of 18 U.S.C. § 287, fals , fictitious or fraudulent claims, and/or constitute
property traceable to such property.
78.
Pursuant to 18 U.S.C. § 981(a)(l) A), "[a]ny property, real or personal, involved in
a transaction or attempted transaction in violation of [18 U.S.C. §§ 1956 and 1957], or any property
traceable to such property" is subject to forfeitur to the United States.
79.
Pursuant to 18 U.S.C. § 981(a)( )(C), "[a]ny property, real or personal, which
constitutes or is derived from proceeds traceable to any violation of .. . any offense constituting
'specified unlawful activity' . .. , or a conspirac to commit such offense" is subject to forfeiture
to the United States.
1
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Case 5:23-cv-00393 Document 1 Fil d 05/17/23 Page 13 of 18 PagelD #: 13
80.
Accordingly, the Defendant As ts and all property traceable thereto are subject to
condemnation and to forfeiture to the United St tes, in accordance with 18 U.S.C. §§ 981(a)(l)(A)
and 981(a)(l)(C).
Count Two--Public mon
or records
81.
The United States incorporates y reference paragraphs 1 through 80 above as if
fully set forth herein.
82.
Pursuant to 18 U.S.C. § 641, it i a federal crime to "embezzle[], steal[], purloin[],
or knowingly convert[] to his use or the use f another, or without authority, sells, conveys or
disposes of any record, voucher, money, or thin of value of the United States or of any department
or agency thereof, or any property made or bei
made under contract for the United States or any
department or agency thereofl:.]"
83.
As set forth above, Bailey kno ingly stole or knowingly converted to his use or
use of another without authority money of the
nited States made or being made under contract
for the United States in violation of 18 U.S. C.
641, public money, property or records.
84.
Pursuant to 18 U.S.C. § 981(a)(l (A), "[a]ny property, real or personal, involved in
a transaction or attempted transaction in violatio of [18 U.S.C. §§ 1956 and 1957], or any property
traceable to such property" is subject to forfeit e to the United States.
85.
Pursuant to 18 U.S.C. § 981(a (l)(C), "[a]ny property, real or personal, which
constitutes or is derived from proceeds traceab e to any violation of ... any offense constituting
'specified unlawful activity' .. . , or a conspira y to commit such offense" is subject to forfeiture
to the United States.
3
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Case 5:23-cv-00393 Document 1 Fil d 05/17/23 Page 14 of 18 PagelD #: 14
86.
Accordingly, the Defendant As ets and all property traceable thereto are subject to
condemnation and to forfeiture to the United St tes, in accordance with 18 U.S.C. §§ 981(a)(l)(A)
and 98l(a)(l)(C).
Count lbree----Fraud b
• e radio or television
87.
The United States incorporates y reference paragraphs 1 through 86 above as if
fully set forth herein.
88.
Pursuant to 18 U.S.C. § 1343, it i a federal crime to "devise[], or intend[] to devise
any scheme or artifice to defraud, or for obt ining money or property by means of false or
fraudulent pretenses, representations, or promis s, transmits or causes to be transmitted by means
of wire .. .in interstate or foreign commerce ... fo the purpose of executing such scheme or artifice.
"
89.
As set forth above, Bailey devis d or intended to devise any scheme or artifice to
defraud, or for obtaining money or propert
by means of false or fraudulent pretenses,
representations, or promises, transmits or causes o be transmitted by means of wire for the purpose
of executing such scheme or artifice in violatio of 18 U.S.C. § 1343, fraud by wire, radio, or
television.
90.
Pursuant to 18 U.S.C. § 981(a)(l) A), "[a]ny property, real or personal, involved in
a transaction or attempted transaction in violation of [18 U.S.C. §§ 1956 and 1957], or any property
traceable to such property" is subject to forfeitur to the United States.
91.
Pursuant to 18 U.S.C. § 98l(a)( )(C), "[a]ny property, real or personal, which
constitutes or is derived from proceeds traceable to any violation of ... any offense constituting
'specified unlawful activity' ... , or a conspirac to commit such offense" is subject to forfeiture
to the United States.
1
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Case 5:23-cv-00393 Document 1 Fil d 05/17/23 Page 15 of 18 PagelD #: 15
92.
Accordingly, the Defendant Ass ts and all property traceable thereto are subject to
condemnation and to forfeiture to the United St tes, in accordance with 18 U.S.C. §§ 981(a)(l)(A)
and 981(a)(l)(C).
CountFour- Launde·
instruments
93.
The United States incorporates y reference paragraphs 1 through 92 above as if
fully set forth herein.
94.
Pursuant to 18 U.S.C. § 1956, t is a federal crime "knowing that the property
involved in a financial transaction represents
e proceeds of some form of unlawful activity,
conducts or attempts to conduct such a financial ransaction which in fact involves the proceeds of
specified unlawful activity-(a)(i) with the inte to promote the carrying on of specified unlawful
activity; or . . . (B) knowing that the transaction s designed in whole or in part---{i) to conceal or
disguise the nature, the location, the source, t e ownership, or the control of the proceeds of
specified unlawful activity."
95.
As set forth above, Bailey knew e Defendant Assets represented the proceeds of
unlawful activity and knew that the transactions were designed in whole or in part to conceal or
disguise the nature, location, the source, the o
ership, or the control of the Defendant Assets of
specified unlawful activity in violation of 18 U. .C. § 1956, laundering of monetary transactions.
96.
Pursuant to 18 U.S.C. § 98l(a)(l) A), "[a]ny property, real or personal, involved in
a transaction or attempted transaction in violation f [18 U.S.C. §§ 1956 and 1957], or any property
traceable to such property" is subject to forfeitur to the United States.
97.
Pursuant to 18 U.S.C. § 98l(a)( )(C), "[a]ny property, real or personal, which
constitutes or is derived from proceeds traceable to any violation of ... any offense constituting
1
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Case 5:23-cv-00393 Document 1 Fil d 05/17/23 Page 16 of 18 PagelD #: 16
'specified unlawful activity' ... , or a conspira y to commit such offense" is subject to forfeiture
to the United States.
98.
Accordingly, the Defendant Ass ts and all property traceable thereto are subject to
condemnation and to forfeiture to the United St es, in accordance with 18 U.S.C. §§ 98l(a)(l)(A)
and 98l(a)(l)(C).
Count Five- Engaging in mone
transactions in property derived
from s ecified unlawful activi
99.
The United States incorporates y reference paragraphs I through 98 above as if
fully set forth herein.
100.
Pursuant to 18 U.S.C. § 1957, t is a federal crime to "knowingly engage[] or
attempt[] to engage in a monetary transaction in riminally derived property of a value greater than
$10,000 and is derived from specified activity."
101.
As set forth above, Bailey knowi gly engaged or attempted to engage in a monetary
transaction in criminally derived property of av ue greater than $10,000.00 and was derived from
specified unlawful activity in violation of 18 U. .C. § 1957, engaging in monetary transactions in
property derived from specified unlawful activi
102.
Pursuant to 18 U.S.C. § 981(a)(l) A), "[a]ny property, real or personal, involved in
a transaction or attempted transaction in violatio of [18 U.S.C. §§ 1956 and 1957], or any property
traceable to such property" is subject to forfeitur to the United States.
103.
Pursuant to 18 U.S.C. § 981(a)( )(C), "[a]ny property, real or personal, which
constitutes or is derived from proceeds traceabl to any violation of ... any offense constituting
'specified unlawful activity' . . . , or a conspirac to commit such offense" is subject to forfeiture
to the United States.
1
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Case 5:23-cv-00393 Document 1 Fil d 05/17/23 Page 17 of 18 PagelD #: 17
104.
Accordingly, the Defendant As ets and all property traceable thereto are subject to
condemnation and to forfeiture to the United St tes, in accordance with 18 U.S.C. §§ 981(a)(l)(A)
and 981(a)(l)(C).
V.
C
105.
By virtue of the foregoing and ursuant to 18 U.S.C. $ 981 (f), all right, title and
interest in the Defendant Assets vested in the
nited States at the time of the commission of the
unlawful acts giving rise to forfeiture has beco e and is forfeitable to the United States.
WHEREFORE, Plaintiff, the United Sta es of America requests that: the Clerk of the Court
issue warrants for arrest of Defendant Assets ( 168,849.42 seized from First Community Bank,
account number XX:2781; and $299,604.40 sei ed from First Community Bank, account number
XX:2660; except for $2,333,832.28 cash frozen om Ally Invest Securities, LLC, account number
XXX-X6295-l l; and $45,000.00 securities fr zen from Ally Invest Securities, LLC, XXX-
X6295-l 1 that this Honorable Court issue a wa ant for the arrest of Ally Invest Securities, LLC,
account XXX-X6295-1 l; that notice of this act on be provided to persons known or thought to
have an interest in or right against the Defenda t Assets; that the Defendant Assets be forfeited
and condemned to the United States; and such o er and further relief as it deems proper and just.
WI LIAM S. THOMPSON
Uni ed States Attorney
By:
/s/C risto her R. Arthur
CH
STOPHERR. ARTHUR (W.Va. Bar# 9192)
Ass stant United States Attorney
300 irginia Street, East, Room 4000
Ch leston, WV 25301
Tel hone: 304-345-2200
1
Case 5:23-cv-00393 Document 29-1 Filed 06/23/26 Page 27 of 29 PageID #: 154

Case 5:23-cv-00393 Document 1 Fil d 05/17/23 Page 18 of 18 PagelD #: 18
STATE OF WEST VIRGINIA
COUNTY OF KANAWHA, TO-WIT:
VERI !CATION
I, Timothy C. Butler, financial forensic investigator from the Office of the West Virginia
State Auditor's Financial Forensics Team-Pu lie Integrity and Fraud Unit, detailed to the Office
of the United States Attorney in the Southern istrict of West Virginia, declare under penalty of
perjury as provided by 28 U.S.C. § 1746, the fi lowing:
That the foregoing Complaint for Forfe' ure in rem is based upon reports and information
I have gathered and which have been provided o me by various law enforcement personnel, and
that everything contained therein is true and co
ct to the best of my knowledge and belief, except
where stated to be upon information and belief, n which case I believe it to be true.
Executed on May _t_1_, 2023.
Taken, subscribed and sworn to before
e this 11-1::hday of May, 2023.
~~~
Notary Public
1
Case 5:23-cv-00393 Document 29-1 Filed 06/23/26 Page 28 of 29 PageID #: 155

JS 44 (Rev. 06/1 7)
Case 5:23-cv-00393
Page 1 of 1 PagelD #: 19
The JS 44 civil cover sheet and the information contained herein neither replace nor supplement the fi lin~ and service of pleadings or other papers as required by law, except as
provided by local rules of court. This form, approved by the Judicial Conference of the United States in ::,eptember 1974, is required for the use of the Clerk of Court for the
purpose of initiating the civil docket sheet. (SEE INSTRUCTIONS ON NEXT PAGE OF 7HI ' FOl?M.)
I. (a) PLAINTIFFS
United States of America
DEFENDANTS
$168,849.42 SEIZED FROM FIRST COMMUNITY BANK,
ACCOUNT NUMBER XX2781 ;
(b) County of Residence of First Listed Plaintiff
County of Residence of First Listed Defendant
_R_a_l_e~iq~h _ ______ _
(I.:.'XG'PT IN U.S. PLAJNTIFF CASES)
( C) Attorneys (Firm Name, Address, and Telephone Number)
(IN U.S. PLAIN11FF CASES ONLY}
NOTE:
IN LAND CONDEMNATION CASES, USE THE LOCATION OF
THE TRACT OF LAND TNVOL YEO.
Attorneys (If Known)
II. BASIS OF JURISDICTION (Place an "X" in One Box Only)
III. ::::JTIZENSHIP OF PRINCIPAL PARTIES (Place an "X" in One Box for Plaintiff
~ I
U.S. Government
Plaintiff
0 2
U.S. Government
Defendant
0 3
Federal Question
(U.S. Government Not a Party)
0 4
Diversity
(Indicate Citizenship of Parties in Item Ill}
(For Diversity Cases Only)
and One Boxjor Defendant)
PTF
DEF
PTF
DEF
C izen of This State
O I
O
I
Incorporated or Principal Place
O 4
0 4
Ci izen of Another State
Ci izen or Subject of a
~oreign Country
0 2
0 3
of Business In This State
0
2
Incorporated and Principal Place
of Business In Another State
0
3
Foreign Nation
0 5
0 5
0 6
0 6
IV. NATURE OF SUIT (Place an "X" in One Box Only)
Click here for: Nature of Suit Code Descrintions.
I
CONTRACT
TORTS
l<ORFEITURE/PENAL TY
BANKRUPTCY
OTHER STATUTES
0 I IO Insurance
0 120 Marine
0 130 Miller Act
0 140 Negotiable Instrument
0 150 Recovery of Overpayment
& Enforcement of Judgment
0 151 Medicare Act
0 I 52 Recovery of Defaulted
Student Loans
(Excludes Veterans)
0 153 Recovery of Overpayment
of Veteran 's Benefits
0 I 60 Stockholders' Suits
0 190 Other Contract
0 195 Contract Product Liability
0 196 Franchise
PERSONAL INJURY
PERSONAL INJURY
O p25 Dmg Related Seizure
O 422 Appeal 28 USC 158
0 375 False Claims Act
0 310 Airplane
O 365 Personal Injury -
of Property 2 1 USC 88 1
0 423 Withdrawal
O 376 Qui Tam (31 USC
0 315 Airplane Product
Product Liability
~ p90 Other
28 USC 157
3729(a))
Liability
O 367 Health Care/
0 400 State Reapportionment
0 320 Assault, Libel &
Phannaceutical
t---=p"'R""O""P""E""R"'T"'Y"'""R""I""G""H==T"'S,------1 0 4 10 Antitmst
Slander
Personal Injury
O 820 Copyrights
O 430 Banks and Banking
0 330 Federal Employers'
Product Liability
O 830 Patent
O 450 Commerce
Liability
O 368 Asbestos Personal
O 835 Patent - Abbreviated
O 460 Deportation
0 340 Marine
Injury Product
New Drug Application
O 470 Racketeer Influenced and
0 345 Marine Product
Liability
O 840 Trademark
Corrupt Organizations
Liability
PERSONAL PROPERTY t--+-----=La.aAaaaB_.,O,.,R.,_ ___ -+--'S""'O~C=IA~L=S~E_.,C~U~R~I~TY~----1 O 480 Consumer Credit
0 350 Motor Vehicle
O 370 Other Fraud
O
10 Fair Labor Standards
O 861 HIA (1 395ft)
0 490 Cable/Sat TV
0 355 Motor Vehicle
O 37 1 Truth in Lending
Act
O 862 Black Lung (923)
0 850 Securities/Commodities/
Product Liability
O 380 Other Personal
O
20 Labor/Management
O 863 DIWC/DIWW (405(g))
Exchange
0 360 Other Personal
Property Damage
Relations
O 864 SSlD Title XVI
O 890 Other Statutory Actions
Injury
O 385 Property Damage
O 40 Railway Labor Act
O 865 RSI ( 405(g))
0 89 1 Agricultural Acts
0 362 Personal Injury -
Product Liability
O
51 Family and Medical
O 893 Environmental Matters
Medical Malpractice
Leave Act
O 895 Freedom of Infonnation
l'--_...;.:RE
:a:.:..:Aa:cL:...:P:...:R,:.;O::..P;:..E
aaR:.:T.:..Y-=----+-----"C"-IV
.,_I:.:L:...R:.:.:.;IG"'H"'T
,a.a;.S __ .,._P'-R=IS:.:O""N-"E"'Rc:...:.P.:::Ec.:.T.:..IT::..:I:..;;Oa.:.N.:..:S'-1 O 90 Other Labor Litigation
1---F- E_D_E_RA
__
L_T_A_X--SU
____
IT_,,S,----1
Act
0 2 10 Land Condemnation
0 220 Foreclosure
0 230 Rent Lease & Ejectment
0 240 Torts to Land
0 245 Tort Product Liability
0 290 All Other Real Property
0 440 Other Civil Rights
Habeas Corpus:
0 441 Voting
O 463 Alien Detainee
0 442 Employment
O 510 Motions to Vacate
0 443 Housing/
Sentence
Accommodations
O 530 General
0 445 Amer. w/Disabilities - 0 535 Death Penalty
Employment
0 446 Amer. w/Disabilities -
Other
0 448 Education
Other:
0 540 Mandamus & Other
0 550 Civil Rights
0 555 Prison Condition
0 560 Civil Detainee -
Conditions of
Confinement
V. ORIGIN (Place an "X" in One Box Only)
0 ,~ I Employee Retirement
O 870 Taxes (U.S. Plaintiff
O 896 Arbitration
Income Security Act
or Defendant)
0 899 Administrative Procedure
IMMIGRATION
0 4D2 Naturalization Application
0 4 D5 Other Immigration
Actions
0 87 1 IRS- Third Party
Act/Review or Appeal of
26 USC 7609
Agency Decision
0 950 Constitutionality of
State Statutes
~ I Original
O 2 Removed from
Proceeding
State Court
0
3
Remanded from
Appellate Court
0 4 Reir stated or
Reo ened
0 5 Transferred from
Another District
(specify)
0 6 Multidistrict
Litigation -
Transfer
0 8 Multidistrict
Litigation -
Direct File
Cite the U.S. Civil Statute under which you are filing (,~o 1101 citej11risdictio11al statutes 1111/ess diversity):
I
VJ. CA USE OF ACTION 1-1.;..c8c.....U=.""S""". C"" ..... ~ ....
,~-"2=8-"-7'-'6'--'4-'-1,._1.;..c3'--'4=3,._1.;..c9;..;:5=6...;;a""'n=d....;.1=95"'-!
7'------------------------
Brief description of cause:
Fraud
VII. REQUESTED IN
COMPLAINT:
0
CHECK IF THIS IS A CLASS ACTION
UNDER RULE 23, F.R.Cv.P.
D 1',MAND $
VII I. RELATED CASE(S)
JF ANY
(See inst111ctions):
DATE
FOR OFFICE USE ONLY
RECEIPT #
AMOUNT
JUDGE John T. Copenha1, er, Jr.
SIGNATURE OF ATTORNEY Cf RECORD
APPL YING lFP
CHECK YES only if demanded in complaint:
JURY DEMAND:
0 Yes
)(! No
DOCKET NUMBER 2:20-cr-00173
-------------
JUDGE
MAG. JUDGE
Case 5:23-cv-00393 Document 29-1 Filed 06/23/26 Page 29 of 29 PageID #: 156

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U.S. Small Business Administration's Petition for Remission of Seized Property (Exhibit A) — United States v. $168,849.42 Seized from First Community Bank, et…

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