Indictment — United States v. Walsh

Record facts

United States District Court, Middle District of Florida, Tampa Division · No. 8:26-cr-00083-KKM-LSG · Doc. 1 · 2026-03-10 · Docket on CourtListener

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Case 8:26-cr-00083-KKM-LSG Document1 Filed 03/10/26 Page1of14PagelD 1

MAR 10 2026 2x2:00 ;
FILED - USC - FLD - TPR

UNITED STATES DISTRICT COURT
MIDDLE DISTRICT OF FLORIDA

TAMPA DIVISION
UNITED STATES OF AMERICA
v. CASE NO. 8 '26-¢¢-¥3-kem-L6q
CALEB WALSH 18 U.S.C. § 1344
(Bank Fraud)
18 U.S.C. § 1343
(Wire Fraud)

18 U.S.C. § 1957
(Illegal Monetary Transactions)
INDICTMENT

The Grand Jury charges:

COUNTS ONE THROUGH SIX
(Bank Fraud)

A. Introduction

At times relevant to this Indictment:

1. CALEB WALSH, a resident of the Middle District of Florida,
submitted false and fraudulent information to obtain federal Paycheck Protection
Program (“PPP”) loans on behalf of his companies, to which he was not entitled.

2. Columbus Partners Community Trust (hereinafter: “Columbus
Partners”) was a Florida Fictitious Entity with JohnRuth Capital, Inc. listed as the
owner with the Florida Division of Corporations. Columbus Partners was located in
the Middle District of Florida. Columbus Partners maintained a corporate bank

account at Financial Institution 1 ending in x1843.
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3. JohnRuth Capital, Inc. (hereinafter: “JohnRuth”) was a Florida
corporation owned by CALEB WALSH located in the Middle District of Florida.
JohnRuth maintained a corporate bank account at Financial Institution 1 ending in
x7029.

4. Midwest by South, LLC (hereinafter: “Midwest”) was a Florida limited
liability company organized and controlled by CALEB WALSH located in the
Middle District of Florida. Midwest purportedly maintained a corporate bank
account at Financial Institution 1 ending in x8768, but actually maintained a
corporate bank account at Financial Institution 2 ending in x6736.

5. Urban Bay Housing Fund, LLC (hereinafter: “Urban Bay”) was a
Florida limited liability company organized and controlled by CALEB WALSH
located in the Middle District of Florida. Urban Bay maintained a corporate bank
account at Financial Institution 3 ending in x4440.

6. Parks Management, LLC was a Florida limited liability company
organized and controlled by CALEB WALSH located in the Middle District of
Florida. Parks Management maintained a corporate bank account at Credit Union 1
ending in x8405.

7. CALEB WALSH and D.W. maintained a joint bank account ending in

x5143 at Financial Institution 4.
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The Small Business Administration

8. 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.

9. In or around March 2020, the President declared the ongoing
Coronavirus Disease 2019 (“COVID-19”) pandemic of sufficient severity and
magnitude to warrant an emergency declaration for all states, tribes, territories, and
the District of Columbia pursuant to section 501(b) of the Robert T. Stafford Disaster
Relief and Emergency Assistance Act, 42 U.S.C. §§ 5121-5207. The President also
signed into law the Coronavirus Aid, Relief, and Economic Security (“CARES”) Act
and the Families First Coronavirus Response Act.

10. The SBA enabled and provided for loans through banks, credit unions,
and other lenders. These loans had government-backed guarantees. In addition to
traditional SBA funding programs, The CARES Acct, established several new
temporary programs and provided for the expansion of others to address the
COVID-19 outbreak, which was declared a nationwide disaster by the President on
March 13, 2020.

11. One of the new loan programs was the SBA PPP, which was a loan
designed, in part, to provide a direct incentive for small businesses to keep their
workers on the payroll. Under this program, the SBA could forgive all or part of the
borrowing businesses’ loans provided that employees were kept on the payroll for

eight weeks and borrowers submitted documentation confirming that the loan
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proceeds were used for certain qualifying business expenses (i.e., payroll, rent,
mortgage interest, or utilities).

12. Interested applicants applied through an existing SBA lender or any
other participating federally-insured financial institution. The PPP application
process required applicants to submit a Borrower Application Form through an SBA-
approved financial entity. The application contained information as to the purpose of
the loan, average monthly payroll, number of employees, and background of the
business and its owner. Applicants were also required to make certain good faith
certifications, including that economic uncertainties had necessitated their loan
requests for continued business operations, and that they intended to use loan
proceeds only for the authorized purposes.

| The PPP Lenders

13. Lender 1 was a financial institution, the deposits and accounts of which
were insured by the Federal Deposit Insurance Corporation that participated in the
SBA’s PPP as a lender, and as such, was authorized to lend funds to eligible
borrowers under the terms of the PPP.

14. Lender 2 was a financial institution, the deposits and accounts of which
were insured by the Federal Deposit Insurance Corporation that participated in the
SBA’s PPP as a lender, and as such, was authorized to lend funds to eligible
borrowers under the terms of the PPP.

15. Lender 3 was a financial institution, the deposits and accounts of which

were insured by the Federal Deposit Insurance Corporation that participated in the

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SBA’s PPP as a lender, and as such, was authorized to lend funds to eligible
borrowers under the terms of the PPP.

16. Lender 4 was a federally-chartered credit union, the deposits and
accounts of which were insured by the National Credit Union Administration Share
Insurance Fund (“NCUA”) that participated in the SBA’s PPP as a lender, and as
such, was authorized to lend funds to eligible borrowers under the terms of the PPP.

17. Lender 5 participated in the SBA’s PPP as a lender, and as such, was
authorized to lend funds to eligible borrowers under the terms of the PPP.

B. The Scheme and Artifice

18. Beginning on an unknown date, but no later than in or around March
2020, and continuing through at least in or around March 2021, in the Middle
District of Florida and elsewhere, the defendant,

CALEB WALSH,
did knowingly and intentionally devise and intend to devise a scheme and artifice to
defraud Lenders 1 through 4, financial institutions, and to obtain monies, funds,
credits, assets, and other property owned by, and under the custody and control of
said financial institutions, by means of materially false and fraudulent pretenses,
representations and promises.
C. Manner and Means of the Scheme and Artifice
19. The manner and means by which the defendant sought to accomplish

the scheme and artifice included, among others, the following:
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a. It was part of the scheme and artifice that the defendant would
and did prepare and submit, and cause to be prepared and submitted, materially false
and fraudulent applications to the PPP, which program was tailored to provide
benefits and relief to businesses and workers negatively impacted by the COVID-19
pandemic.

b. It was further a part of the scheme and artifice that, in order to
induce the PPP Lenders to fund the PPP loans, the defendant would and did prepare
and submit, and cause to be prepared and submitted, to the PPP Lenders
applications that contained multiple materially false and fraudulent representations

and pretenses, including:

1. overstating the number of employees for the business;
il. overstating the average monthly payroll for the business;
iii. representing and certifying that loan proceeds would be
used for authorized PPP purposes; and
iv. fraudulently affirming the truth of statements in the
applications.

c. It was further a part of the scheme and artifice that the defendant

would and did submit fraudulent supporting documentation, including, but not

limited to:
i. 2019 IRS Form 940, Employer’s Annual Federal
Unemployment Tax Returns;
il. 2020 IRS Form 941, Employer’s Quarterly Federal Tax
Returns;
iil. IRS Form 1040-X and Schedule C for tax year 2019;
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iv. Altered corporate bank statements showing inflated
balances; and

Vv. Fictitious corporate bank statements showing balances for
non-existent accounts.

d. It was further a part of the scheme and artifice that the defendant
would and did cause the PPP Lenders to approve the PPP loan application and cause
to be transmitted PPP loan proceeds to corporate bank accounts controlled by the
defendant.

e. It was further a part of the scheme and artifice that the defendant
would and did use the PPP funds, and cause the PPP funds to be used, for
unauthorized purposes and for his own personal enrichment.

f. It was a further part of the scheme and artifice that the defendant
would and did perform acts and make statements to promote and achieve the scheme
and artifice and to misrepresent, hide, and conceal the scheme and artifice and the
acts committed in furtherance thereof.

D. Execution of the Scheme and Artifice
20. Onor about the date set forth below in each count, in the Middle
District of Florida and elsewhere, the defendant,
CALEB WALSH,
for the purpose of executing and attempting to execute the aforesaid scheme and
artifice, knowingly and intentionally obtained moneys, funds, credits, assets,
securities and other property owned by and under the custody and control of

financial institutions whose deposits were insured by the FDIC on NCUA, by means
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of materially false and fraudulent pretenses, representations, and promises, as
described above, in that CALEB WALSH caused, and attempted to cause, the

following PPP loans to be approved and funded:

) ONE “April 30, 2020 «| $725, 000 First Draw PPP loan from Lender 1 I
in the name of Columbus Partners

TWO May 28, 2020 $722,000 First Draw PPP loan from Lender 1
in the name of Midwest

THREE | February 18, 2021 | $722,000 Second Draw PPP loan from
Lender 2 in the name of Midwest

FOUR June 19, 2020 $722,792 First Draw PPP loan from Lender 3
in the name of Urban Bay

FIVE March 17, 2021 $1,037,624 Second Draw PPP loan from
Lender 3 in the name of Urban Bay

SIX May 1, 2020 $168,630 First Draw PPP loan from Lender 4
in the name of Parks Management, LLC

All in violation of 18 U.S.C. § 1344.

COUNT SEVEN
(Wire Fraud)

A. Introduction

1. The Grand Jury hereby realleges paragraphs 1 through 19 of Counts
One through Six of this Indictment and incorporates such paragraphs by this
reference as though fully set forth herein.
B. The Scheme and Artifice

2. Beginning on an unknown date, but no later than in or around March
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2020, and continuing through March 2021, in the Middle District of Florida and
elsewhere, the defendant,
CALEB WALSH,
did knowingly and intentionally devise and intend to devise a scheme and artifice to
defraud, and for obtaining money and property by means of false and fraudulent
pretenses, representations, and promises about a material fact.
C. Manner and Means of the Scheme
3. The manner and means of the scheme and artifice are set forth in
Paragraph 19 of Counts One through Six of this Indictment, the allegations of which
are realleged and incorporated by reference as if fully set forth herein.
D. Execution of the Scheme and Artifice
4, On or about the date set forth below in each count, in the Middle
District of Florida and elsewhere, the defendant,
CALEB WALSH,
for the purpose of executing the aforesaid scheme and artifice, knowingly and
intentionally transmitted and caused to be transmitted by means of wire
communication in interstate and foreign commerce the writings, signs, signals,
pictures, and sounds described below, each transmission constituting a separate

count:
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COUNT | DATE OF WIRE DESCRIPTION OF WIRE

Defendant caused a $725,187 interstate wire transfer
of PPP funds, sent by Lender 5 from outside Florida
SEVEN May 4, 2020 to the JohnRuth Financial Institution 1 account
ending in x7029 controlled by the defendant within
the Middle District of Florida

All in violation of 18 U.S.C. § 1343.

COUNTS EIGHT THROUGH FOURTEEN
(Illegal Monetary Transactions)

1. Paragraphs | through 19 of Counts One through Six and paragraphs 1
through 4 of Count Seven of this Indictment are realleged and incorporated by
reference as if fully set forth herein.

2. On or about the dates listed below, in the Middle District of Florida and
elsewhere, the defendant,

CALEB WALSH,
aided and abetted by others, did knowingly engage and attempt to engage in a
monetary transaction, in and affecting interstate commerce, in criminally derived
property of a value greater than $10,000.00, such property having been derived from
specified unlawful activity, as described below, knowing that such transaction
involved property and funds that were the proceeds obtained from a criminal offense,

as follows:

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Filed 03/10/26

Page 11 of 14 PagelD 11

EIGHT May 7, 2020 Bank fraud, + $100000 electronic fonds
in violation of | transfer to a real estate
18 U.S.C. § settlement services company
1344 to partially fund the
purchase of a motel located
in Lincoln, Nebraska with
funds from the Credit Union
1 account ending in x8405.
NINE May 14, 2020 Bank fraud, $65,000 check from the
in violation of | Financial Institution 4
18 U.S.C. § account ending in x5143
1344 made payable to Mercedes-
Benz of Tampa to purchase
a 2020 Mercedes Benz G550
SUV.
TEN May 21, 2020 Wire fraud, $807,258.36 electronic funds
in violation of | transfer to a real estate
18 U.S.C. § settlement services company
1343 and Bank | to fund the purchase of a
fraud, Motel located in Lincoln,
in violation of | Nebraska with funds from
18 U.S.C. § the Financial Institution 1
1344 account ending in x7029.
ELEVEN March 8, 2021 ‘| Bank fraud, $15,600 Visa debit card
in violation of | charge to a private jet charter
18 U.S.C. § company to fund a private
1344 jet trip to and from Mexico
with funds from the
Financial Institution 4
account ending in x8250.
TWELVE March 19, 2021 | Bank fraud, $117,534 electronic funds
in violation of | transfer to a cryptocurrency
18 U.S.C. § exchange to fund the
1344 purchase of Bitcoin (Symbol:
BTC) with funds from the
Financial Institution 4
account ending in x5143.

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All in violation of 18 U.S.C. §§ 1957 and 2.

FORFEITURE

1. The allegations contained in Counts One through Twelve are
incorporated by reference for the purpose of alleging forfeiture pursuant to 18 U.S.C.
§ 981(a)(1)(C), 18 U.S.C. § 982(a)(1), and 28 U.S.C. § 2461(c).

2. Upon conviction of a violation of 18 U.S.C. § 1343 and/or 18 U.S.C. §
1344 the defendant shall forfeit to the United States, pursuant to 18 U.S.C. §
981(a)(1)(C) and 28 U.S.C. § 2461(c), any property, real or personal, which
constitutes or is derived from proceeds traceable to the violations.

3. Upon conviction of a violation of 18 U.S.C. § 1957, the defendant[s]
shall forfeit to the United States, pursuant to 18 U.S.C. § 982(a)(1), any property, real
or personal, involved in such offense, or any property traceable to such property.

4. The property to be forfeited includes, but is not limited to, the following
assets:

a. An order of forfeiture of at least $4,823,233 which represents the
amount of proceeds traceable to the violations;

b. A 2020 Mercedes Benz G550 SUV;
c. $117,534 in Bitcoin cryptocurrency;

d. The real property located at located at 3400 NW 12" Street in
Lincoln, NE, including all appurtenances thereto and
improvements thereon.

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3. If any of the property described above, as a result of any act or omission

of the defendant:

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,

the United States shall be entitled to forfeiture of substitute property pursuant to 21

U.S.C. § 853(p), as incorporated by 28 U.S.C. § 2461(c).

By:

GREGORY W. KEHOE
United States Attorney

bin JY,

Christopher Poor
Assistant United States Attorney

BBS

Gregory Pizzo
Assistant United States Attorney
Chief, Economic Crimes Section

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FORM OBD-34

February 26 No.

UNITED STATES DISTRICT COURT
Middle District of Florida
Tampa Division

THE UNITED STATES OF AMERICA

VS.

CALEB WALSH

INDICTMENT

Violations: 18 U.S.C. § 1344, 18 U.S.C. § 1343
18 U.S.C. § 1957

A true / -

Foreperson

Filed in open court this 10" day

of March 2026.

Clerk

Bail $

GPO 863 525

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