Information — United States v. Aaron Ashcraft

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U.S. District Court, Eastern District of California · No. 2:22-cr-00087-KJM · Doc. 1 · 2022-04-25 · Docket on CourtListener

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PHILLIP A. TALBERT 
United States Attorney 
MATTHEW THUESEN 
Assistant United States Attorney 
501 I Street, Suite 10-100 
Sacramento, CA 95814 
Telephone:  (916) 554-2700 
Facsimile:   (916) 554-2900  
 
Attorneys for Plaintiff 
United States of America 
 
IN THE UNITED STATES DISTRICT COURT 
EASTERN DISTRICT OF CALIFORNIA 
 
UNITED STATES OF AMERICA, 
                                              Plaintiff, 
                                    v. 
AARON ASHCRAFT,  
                                             Defendant. 
CASE NO.   
18 U.S.C. § 1343 – Wire Fraud (2 Counts); and 
18 U.S.C. § 1344 – Bank Fraud (5 Counts) 
 
I N F O R M A T I O N 
 
COUNTS ONE AND TWO: [18 U.S.C. § 1343 – Wire Fraud] 
 
The United States Attorney charges: 
  
AARON ASHCRAFT, 
defendant herein, as follows: 
INTRODUCTION 
At all relevant times,  
1. 
AARON ASHCRAFT was a resident of Sacramento, California. 
The Small Business Administration 
2. 
The United States Small Business Administration (“SBA”) was an executive-branch 
agency of the United States government that provided support to entrepreneurs and small businesses. 
The mission of the SBA was to maintain and strengthen the nation’s economy by enabling the 
2:22-cr-0087 KJM
FILED
Apr 25, 2022
CLERK, U.S. DISTRICT COURT 
EASTERN DISTRICT OF CALIFORNIA
Case 2:22-cr-00087-KJM   Document 1   Filed 04/25/22   Page 1 of 10

 
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establishment and viability of small businesses and by assisting in the economic recovery of 
communities after disasters. 
The Paycheck Protection Program 
3. 
The Coronavirus Aid, Relief, and Economic Security (“CARES”) Act was a federal law 
enacted in March 2020 and designed to provide emergency financial assistance to the millions of 
Americans who were suffering the economic effects caused by the COVID-19 pandemic. One source of 
relief provided by the CARES Act was the authorization of forgivable loans to small businesses for job 
retention and certain other expenses, through a program referred to as the Paycheck Protection Program 
(“PPP”). 
4. 
To obtain a PPP loan, a qualifying business was required to submit a PPP loan 
application that was signed by an authorized representative of the business. The PPP loan application 
required the business (through its authorized representative) to acknowledge the program rules and make 
certain affirmative certifications in order to be eligible to obtain the PPP loan. In the PPP loan 
application (SBA Form 2483), the small business (through its authorized representative) was required to 
state, among other things, its: (a) average monthly payroll expenses; and (b) number of employees. 
These figures were used to calculate the amount of money the small business was eligible to receive 
under the PPP. In addition, businesses applying for a PPP loan typically were required to provide 
documentation showing their payroll expenses. 
5. 
A PPP loan application was processed by a participating lender. If a PPP loan application 
was approved, the participating lender funded the PPP loan using its own monies, which were 100 
percent guaranteed by the SBA. Data from the application, including information about the borrower, 
the total amount of the loan, and the listed number of employees, was transmitted by the lender to the 
SBA in the course of processing the loan. 
6. 
PPP loan proceeds were required to be used on certain permissible expenses, including 
payroll costs, mortgage interest, rent, and utilities. Under the applicable PPP rules and guidance, the 
interest and principal on the PPP loan were eligible for forgiveness if the business spent the loan 
proceeds on these expense items within a designated period of time and used a certain portion of the 
loan towards payroll expenses. 
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Lending Institutions 
7. 
Lender 1 was an independent finance provider for small businesses based in California. 
8. 
Lender 2 was an independent finance provider for small businesses based in Florida. 
9. 
Lender 3 was an independent finance provider for small businesses based in California. 
10. 
Bank 1 was a financial institution based in Florida, the deposits of which were insured by 
the Federal Deposit Insurance Corporation (“FDIC”). 
11. 
Lender 1, Lender 2, Lender 3, and Bank 1 were authorized by the SBA to participate as 
PPP lenders to small businesses. 
Purported Businesses 
12. 
AARM, LLC, dba AACIIS Services (“AACIIS”), was a purported business located in 
Sacramento, California.  
13. 
Aarox, Inc., was a purported business located in Sacramento, California.  
14. 
Booktech Enterprises was a purported business located in Grass Valley, California. 
15. 
Eros Productions was a purported business located in Sacramento, California. 
16. 
Tech 1 Engineering was a purported business located in Sacramento, California. 
SCHEME TO DEFRAUD 
17. 
From in or around May 2020 through in or around April 2021, in the State and Eastern 
District of California and elsewhere, AARON ASHCRAFT knowingly and with the intent to defraud 
devised, participated in, executed, and attempted to execute a material scheme and artifice to defraud the 
lending institutions identified in paragraphs 7-10 of this Information and to obtain money and property 
from such lending institutions by means of materially false and fraudulent pretenses, representations, 
and promises, and the concealment of material facts. 
PURPOSE OF THE SCHEME TO DEFRAUD 
18. 
The purpose of the scheme and artifice to defraud was for AARON ASHCRAFT to 
enrich himself unlawfully by obtaining PPP loans through the submission of fraudulent PPP loan 
applications and related materials.  
 
 
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MANNER AND MEANS 
 
In furtherance of the scheme and artifice to defraud, AARON ASHCRAFT employed, among 
others, the following manner and means: 
19. 
AARON ASHCRAFT submitted at least seven fraudulent PPP loan applications to SBA-
approved lenders, some of which were funded, as described below: 
 
Entity 
 
Lender 
Approx. 
Application 
Date 
Approx. 
Amount 
Sought 
Approx. 
Date 
Funded 
Amount 
Funded 
 
Aarox, Inc. 
 
 
Lender 1 
 
5/21/2020 
 
$44,785 
 
5/27/2020 
 
$44,785 
 
AACIIS 
Services 
 
 
Lender 1 
 
5/27/2020 
 
$81,164 
 
6/3/2020 
 
$81,165 
 
Eros 
Productions 
 
 
Lender 1 
 
6/1/2020 
 
$163,034 
 
6/18/2020 
 
$163,035 
 
Booktech 
Enterprises 
 
 
Lender 1 
 
6/7/2020 
 
$303,261 
 
6/30/2020 
 
$303,260 
 
Booktech 
Enterprises 
 
 
Bank 1 
 
6/11/2020 
 
$307,100 
 
N/A 
 
$0 
 
Tech 1 
Engineering 
 
 
Lender 2 
 
2/5/2021 
 
$153,260 
 
2/22/2021 
 
$153,260 
 
Tech 1  
Engineering 
 
 
Lender 3 
 
4/17/2021 
 
$174,093.75 
 
4/21/2021 
 
$174,093.75 
20. 
In the PPP loan applications, AARON ASHCRAFT falsely represented, among other 
things, that each purported business had employees and an average monthly payroll expense, as 
described below, when the purported businesses had no employees and no monthly payroll expenses: 
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Entity 
 
Lender 
Approx. 
Application 
Date 
Purported 
No. of 
Employees 
Purported 
Avg. 
Monthly 
Payroll 
 
Aarox, Inc. 
 
 
Lender 1 
 
5/21/2020 
 
2 
 
$17,914 
 
AACIIS 
Services 
 
 
Lender 1 
 
5/27/2020 
 
4 
 
$32,465.80 
 
Eros 
Productions 
 
 
Lender 1 
 
6/1/2020 
 
8 
 
$65,214 
 
Booktech 
Enterprises 
 
 
Lender 1 
 
6/7/2020 
 
9 
 
$121,304 
 
Booktech 
Enterprises 
 
 
Bank 1 
 
6/11/2020 
 
9 
 
$122,840 
 
Tech 1 
Engineering 
 
 
Lender 2 
 
2/5/2021 
 
11 
 
$61,304 
 
Tech 1  
Engineering 
 
 
Lender 3 
 
4/17/2021 
 
11 
 
$69,638.50 
21. 
To support the PPP loan applications, AARON ASHCRAFT submitted fabricated 
records, including IRS forms, business checking account statements, and payroll summaries.   
22. 
In total, based on the seven fraudulent PPP loan applications AARON ASHCRAFT 
submitted and caused to be submitted, AARON ASHCRAFT fraudulently sought to obtain over 
approximately $1.2 million and obtained over approximately $920,000.  
EXECUTION OF THE SCHEME 
23. 
On or about the dates listed below as to each count, in the State and Eastern District of 
California and elsewhere, for the purpose of executing and attempting to execute the aforementioned 
scheme and artifice to defraud, and to obtain money and property by means of materially false and 
fraudulent pretenses, representations, and promises, and the concealment of material facts, AARON 
ASHCRAFT knowingly transmitted and caused to be transmitted by means of wire communications in 
interstate commerce the following writings, signs, signals, pictures, and sounds: 
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Count 
 
Approx. 
Wire Date 
 
 
Wire Description 
 
 
1 
 
 
 
6/3/2020 
 
ACH transfer of approximately $81,165 from Lender 1 to a 
financial account ending 4409 that AARON ASHCRAFT 
controlled 
 
 
 
2 
 
 
 
6/30/2020 
 
ACH transfer of approximately $303,260 from Lender 1 to a 
financial account ending 7575 that AARON ASHCRAFT 
controlled 
 
All in violation of Title 18, United States Code, Sections 2 and 1343. 
COUNT THREE: [18 U.S.C. § 1344 – Bank Fraud] 
 
The United States Attorney further charges: 
AARON ASHCRAFT 
defendant herein, as follows: 
1. 
Paragraphs 1 through 22 of Counts One and Two of this Information are realleged and 
incorporated by reference as if fully set forth herein. 
2. 
On or about June 11, 2020, in the State and Eastern District of California and elsewhere, 
AARON ASHCRAFT knowingly and with the intent to defraud executed and attempted to execute a 
material scheme and artifice to defraud Bank 1 and to obtain the monies, funds, credits, assets, 
securities, and other property owned by and under the custody and control of Bank 1, by means of 
materially false and fraudulent pretenses, representations, and promises, that is, submission of a 
fraudulent PPP loan application for Booktech Enterprises to Bank 1 for $307,100, in violation of Title 
18, United States Code, Sections 2 and 1344. 
// 
// 
// 
// 
// 
// 
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COUNTS FOUR THROUGH SEVEN: [18 U.S.C. § 1344 – Bank Fraud] 
 
The United States Attorney further charges: 
AARON ASHCRAFT 
defendant herein, as follows: 
INTRODUCTION 
 
At all relevant times: 
1. 
AARON ASHCRAFT was a resident of Sacramento, California. From in or around 
December 2007 through in or around June 2020, AARON ASHCRAFT worked for Company 1, which 
was a street sweeping company located in Sacramento, California. AARON ASHCRAFT held multiple 
positions at Company 1, including chief financial officer. AARON ASHCRAFT’s duties included, 
among other things, accounting, financial reporting, and tax preparation.  
2. 
Company 1 held two business credit card accounts at Bank 2, which was a financial 
institution based in Virginia, the deposits of which were insured by the FDIC. The accounts had multiple 
authorized users with separate credit card numbers. AARON ASHCRAFT was not an authorized user of 
either account. AARON ASHCRAFT did, however, have access to the credit card numbers of 
authorized users. 
3. 
The credit card account numbers ended in 3519 and 9059. 
4. 
AARON ASHCRAFT controlled the following financial accounts: 
a. Bank 3 account ending 6657 (“Bank 3 Account”); 
b. Bank 4 account ending 5236 (“Bank 4 Account”); and 
c. Bank 5 account ending 4409 (“Bank 5 Account”). 
5. 
AARON ASHCRAFT also controlled multiple online payment accounts (each an “Online 
Account” and, collectively, “Online Accounts”). 
SCHEME TO DEFRAUD 
6. 
From in or around September 2017 through June 2020, AARON ASHCRAFT knowingly 
and with the intent to defraud executed and attempted to execute a material scheme and artifice to 
defraud Bank 2 and to obtain the monies, funds, credits, assets, securities, and other property owned by 
and under the custody and control of Bank 2, by means of materially false and fraudulent pretenses, 
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representations, and promises. 
MANNER AND MEANS 
7. 
Without authorization, AARON ASHCRAFT charged the credit card numbers of 
authorized users of Company 1’s Bank 2 credit card accounts to make payments to accounts he 
controlled, including the Bank 3 Account, Bank 4 Account, Bank 5 Account, and Online Accounts. 
8. 
To conceal his fraudulent scheme from Company 1, rather than entering each credit card 
charge separately as an expense in Company 1’s accounting software, AARON ASHCRAFT combined 
the unauthorized charges with legitimate charges as one expense. 
9. 
In total, AARON ASHCRAFT made over 300 fraudulent charges to Company 1’s Bank 2 
credit card accounts. Based on those charges, AARON ASHCRAFT fraudulently obtained from Bank 2 
approximately $780,000.  
EXECUTION OF THE SCHEME 
10. 
On or about the dates listed below as to each count, in the State and Eastern District of 
California and elsewhere, for the purpose of executing and attempting to execute the aforementioned 
scheme and artifice to defraud Bank 2 and to obtain the monies, funds, credits, assets, securities, and 
other property owned by and under the custody and control of Bank 2, by means of materially false and 
fraudulent pretenses, representations, and promises, AARON ASHCRAFT charged the following 
amounts to Company 1’s Bank 2 credit card accounts: 
 
 
Count 
 
Company 1  
Bank 2 Account 
 
Approx. Charge 
Date 
 
 
Charge Amount 
 
Ashcraft Receiving 
Account 
 
4 
 
 
3519 
 
9/13/2017 
 
$1,188 
 
 
Online Payment 
Account 
 
 
5 
 
 
9059 
 
2/4/2020 
 
$3,500 
 
Bank 3 Account 
 
6 
 
 
3519 
 
2/11/2020 
 
$6,455.20 
 
Bank 4 Account 
 
7 
 
 
3519 
 
6/16/2020 
 
$3,256.18 
 
Bank 5 Account 
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All in violation of Title 18, United States Code, Sections 2 and 1344. 
 
 
Dated: April 25, 2022 
 
 
 
 
 
By: 
 
 
PHILLIP A. TALBERT 
United States Attorney 
 
 
 
MATTHEW THUESEN 
Assistant United States Attorney 
 
Case 2:22-cr-00087-KJM   Document 1   Filed 04/25/22   Page 9 of 10

 
 
United States v. Aaron Ashcraft  
Penalties for Information 
Defendant 
Aaron Ashcraft 
 
 
COUNTS 1 and 2: 
 
 
 
VIOLATION:  
18 U.S.C. § 1343 – Wire Fraud 
 
PENALTIES:  
Up to 20 years of imprisonment, or fine up to $250,000, or both; 
 
 
 
Up to 3 years of supervised release; 
 
 
 
Restitution 
 
SPECIAL ASSESSMENT: $100 
 
COUNTS 3-7: 
 
VIOLATION:  
18 U.S.C. § 1344 – Bank Fraud 
 
PENALTIES:   
Up to 30 years of imprisonment, or fine up to $1,000,000, or both; 
 
 
 
Up to 5 years of supervised release; 
 
 
 
Restitution 
 
SPECIAL ASSESSMENT: $100 
 
 
 
Case 2:22-cr-00087-KJM   Document 1   Filed 04/25/22   Page 10 of 10

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