Information — United States v. Bath

Record facts

U.S. District Court, Eastern District of California · No. 1:24-cr-00198-JLT-SKO · Doc. 1 · 2024-08-15 · Docket on CourtListener

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PHILLIP A. TALBERT 
United States Attorney 
JEFFREY A. SPIVAK 
Assistant United States Attorney 
2500 Tulare Street, Suite 4401 
Fresno, CA 93721 
Telephone:  (559) 497-4000 
Facsimile:   (559) 497-4099  
Attorneys for Plaintiff  
United States of America 
IN THE UNITED STATES DISTRICT COURT 
EASTERN DISTRICT OF CALIFORNIA 
UNITED STATES OF AMERICA, 
Plaintiff, 
v. 
GURJEET BATH, 
Defendant. 
CASE NO.   
18 U.S.C. § 641 – Theft of Government Property; and 
18 U.S.C. § 981(a)(1)(C) and 28 U.S.C. § 2461(c) – 
Criminal Forfeiture 
I N F O R M A T I O N 
COUNT ONE: [18 U.S.C. § 641– Theft of Government Property] 
The United States Attorney charges: T H A T 
GURJEET BATH, 
defendant herein, as follows: 
1.
At all relevant times, Defendant Gurjeet Bath operated, himself and with family
members, two trucking businesses:  G.S. Bath, Inc. and Complete Transportation Solutions (CTS), 
operating in Fresno County in the State and Eastern District of California. 
2.
In/around April 20, 2020, Bath caused G.S. Bath, Inc. to apply for and receive a COVID-
19 Paycheck Protection Program ("PPP") loan for approximately $366,000 from the United States Small 
Business Administration ("SBA"). Then, in and around March 10, 2021, Bath caused G.S. Bath, Inc. to 
apply for and receive a PPP loan for approximately $475,000 from the SBA.   
 1:24-cr-00198-JLT-SKO
Case 1:24-cr-00198-JLT-SKO     Document 1     Filed 08/15/24     Page 1 of 4
FILED
Aug 15, 2024
CLERK, U.S. DISTRICT COURT 
EASTERN DISTRICT OF CALIFORNIA

 
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3. 
For the two G.S. Bath, Inc. PPP loans, Bath falsified records he provided to the SBA to 
misrepresent and inflate the number of employees G.S. Bath, Inc. had, and to misrepresent and inflate 
and the gross wages paid by G.S. Bath, Inc.  Bath knew these representations were false at the time he 
made them to the SBA.  Based on Bath’s material misrepresentations, G.S. Bath, Inc.’s PPP loans were 
approved and the SBA transferred to Bath and his family members approximately $366,000 and 
approximately $475,000 which were received and deposited into bank accounts in Fresno County, State 
and Eastern District of California. 
4. 
In/around May 7, 2020, Bath caused CTS to apply for and receive a PPP loan for 
approximately $198,000 from the SBA.  To obtain the loan, Bath knowingly falsified records to 
misrepresent the number of CTS employees and names of those employees, and misrepresent that CTS 
paid gross wages to those employees.  Bath then submitted those falsified records to the SBA.  
5. 
Based on Bath’s material misrepresentations, CTS’s PPP loan was approved and the SBA 
transferred to Bath approximately $198,000 which were received and deposited into bank accounts in 
Fresno County, State and Eastern District of California. 
6. 
Accordingly, between in or around April 20, 2020 and in or around March 10, 2021, Bath 
knowingly stole over $1,000 in funds belonging to the United States, or a department or agency thereof, 
with the intention of depriving the United States of the use or benefit of the money, in violation of 18 
U.S.C. § 641. 
FORFEITURE ALLEGATION:  
[18 U.S.C. § 981(a)(1)(C) and 28 U.S.C. § 2461(c)]  
1. 
Upon conviction of the offenses alleged in Count One of this Information, defendant 
GURJEET BATH shall forfeit to the United States pursuant to 18 U.S.C. § 981(a)(1)(C) and 28 U.S.C. § 
2461(c), all property, real or personal, which constitutes or is derived from proceeds traceable to such 
violation, including, but not limited to, the following: 
a. Real property located at 2745 S. Peach Avenue, Fresno, California, Fresno County, 
APN: 316-040-34,  
b. Real property located at 18670 S. Elm Avenue, Laton, California, Fresno County, 
APNs: 055-310-15 and 055-021-18, and 
c. A sum of money equal to the amount of proceeds traceable to such offenses, for 
which defendant is convicted. 
Case 1:24-cr-00198-JLT-SKO     Document 1     Filed 08/15/24     Page 2 of 4

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If any property subject to forfeiture, as a result of the offenses alleged in Count One of this 
Information, for which defendant is convicted:  
a.
cannot be located upon the exercise of due diligence;
b.
has been transferred or sold to, or deposited with, a third party;
c.
has been placed beyond the jurisdiction of the Court;
d.
has been substantially diminished in value; or
e.
has been commingled with other property which cannot be divided without
difficulty;
it is the intent of the United States, pursuant to 28 U.S.C. § 2461(c), incorporating 21 U.S.C. § 853(p), to 
seek forfeiture of any other property of defendant, up to the value of the property subject to forfeiture. 
Dated:   
By: 
PHILLIP A. TALBERT 
United States Attorney 
JEFFREY A. SPIVAK 
Assistant United States Attorney 
8/15/2024
Case 1:24-cr-00198-JLT-SKO     Document 1     Filed 08/15/24     Page 3 of 4

 
 
United States v. Bath  
Penalties for Information 
 
 
COUNT 1: 
 
 
 
VIOLATION:  
18 U.S.C. § 641 – Theft of Government Property   
 
PENALTIES:  
A maximum of up to 10 years in prison; or 
 
 
 
Fine of up to $250,000; or both fine and imprisonment 
 
 
 
Supervised release of up to 3 years  
 
SPECIAL ASSESSMENT: $100 (mandatory on each count) 
 
 
 
Case 1:24-cr-00198-JLT-SKO     Document 1     Filed 08/15/24     Page 4 of 4

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