Information — United States v. Adam Winston James (N.D. Okla.)

Record facts

U.S. District Court, Northern District of Oklahoma · No. 4:20-cr-00327-GKF · Doc. 2 · 2020-12-15 · Docket on CourtListener

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VA Case,4:20-cr-00327-GKF Document 2 Filed in USDC ND/OK on 12/15/20 Page 1 of 3
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FILED

DEC 1 5 2020

IN THE UNITED STATES DISTRICT COURT Ja“ a Mtgpartt, Glerk
FOR THE NORTHERN DISTRICT OF OKLAHOMA

Case No. 2 0 CR 32 ¢ JED

UNITED STATES OF AMERICA, _)
)
Plaintiff, ) INFORMATION
) [18 U.S.C. § 1028A(a)(1): Aggravated
v. ) Identity Theft;
) Forfeiture Allegation: 18 U.S.C. §§
ADAM WINSTON JAMES, ) 982(a) and 1028(b)(5), and 28 U.S.C.
) § 2461 — Identity Theft Forfeiture]
Defendant. )

THE UNITED STATES ATTORNEY CHARGES:

On or about May 6, 2020, in the Northern District of Oklahoma, the defendant
ADAM WINSTON JAMES (“JAMES”), executed, and attempted to execute, a scheme
and artifice to defraud Regent Bank, a financial institution, and to obtain money and
property from Regent Bank by means of materially false and fraudulent pretenses,
representations, and promises, knowing that the pretenses, representations, and promises
were false and fraudulent when made (“the Scheme”). As part of the Scheme, JAMES
applied for a Paycheck Protection Program (PPP) loan on behalf of a company he claimed
to own and operate, Velocity Innovations LLC. In connection with that application,
JAMES knowingly transferred, possessed, and used, without lawful authority, the means
of identification of other people, known to the United States Attorney and designated
herein as H.R., S.S., M.M., A.J., D.M., G.L., and L.M., during and in relation to a felony
violation enumerated in Title 18, United States Code, Section 1028A(c), namely, Bank
Fraud, in violation of Title 18, United States Code, Section 1344, knowing that the means
of identification belonged to actual people.

All in violation of Title 18, United States Code, Section 1028A(a)(1).
FORFEITURE ALLEGATION
[18 U.S.C. §§ 982(a) and 1028(b)(5), and 28 U.S.C. § 2461(c)]

The allegations contained in this Information are hereby realleged and incorporated
by reference for the purpose of alleging forfeitures pursuant to Title 18, United States Code,
Sections 982(a) and 1028(b)(5), and Title 28, United States Code, Section 2461(c).

Upon conviction of the offense alleged in this Information, as a part of his sentence,
the defendant, ADAM WINSTON JAMES, shall forfeit to the United States, pursuant to
Title 18, United States Code, Sections 982(a) and 1028(b)(5), and Title 28, United States
Code, Section 2461(c), any property constituting, or derived from, or traceable to, the
proceeds obtained, directly or indirectly, as a result of such violations, and personal
property used, or intended to be used, to commit the offense. The property to be forfeited
includes, but is not limited to:

MONEY JUDGMENT

A money judgment in an amount representing proceeds obtained by ADAM
WINSTON JAMES as a result of the aggravated identity theft offense.

Pursuant to Title 21, United States Code, Section 853(p), as incorporated by Title
18, United States Code, Sections 982(b)(1) and 1028(g), and Title 28, United States Code,
Section 2461(c), the defendant shall forfeit substitute property, up to the value of the
property described above if, by any act or omission of the defendant, the property described
above, or any portion thereof, cannot be located upon the exercise of due diligence; has
been transferred or sold to, or deposited with, a third party; has been placed beyond the

jurisdiction of the court; has been substantially diminished in value; or has been
¢

commingled with other property which cannot be divided without difficulty.
All pursuant to Title 18, United States Code, Sections 982(a) and 1028(b)(5), and

Title 28, United States Code, Section 2461(c).

REGAL
ssistant Unilled States Attorney

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