Indictment — United States v. Golden-Larimore et al. (including Henderson) (W.D. Mo.)

Record facts

U.S. District Court for the Western District of Missouri · No. 4:23-cr-00233-BCW · Doc. 1 · 2023-10-18 · Docket on CourtListener

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IN THE UNITED STATES DISTRICT COURT FOR THE 
WESTERN DISTRICT OF MISSOURI 
WESTERN DIVISION 
DEFENDANT NO. 
DEFENDANT NAME 
COUNTS CHARGED 
1 
RENETTA GOLDEN-LARIMORE 
1 - 7 
2 
CAMONTE HENDERSON 
1 & 2, and Forfeiture 
Allegation 
3 
TAJONA MANNING 
1 & 3, and Forfeiture 
Allegation 
4 
TASHAWN MAYFIELD 
1 & 4, and Forfeiture 
Allegation 
5 
QUINNIECE SMITH 
1, 5 & 6, and Forfeiture 
Allegation 
6 
DANNISHA TAYLOR 
1 & 7, and Forfeiture 
Allegation 
UNITED STATES OF AMERICA, 
Plaintiff, 
v. 
RENETTA GOLDEN-LARIMORE (01), 
[DOB:  11/18/1968] 
CAMONTE HENDERSON (02), 
[DOB: 04/19/1998] 
TAJONA MANNING (03), 
[DOB: 09/26/1992] 
TASHAWN MAYFIELD (04), 
[DOB: 04/22/1993] 
QUINNIECE SMITH (05) 
[DOB: 05/14/1990] 
DANNISHA TAYLOR (06) 
[DOB: 01/01/1991] 
Defendants. 
Case No.  
COUNT ONE: 
18 U.S.C. § 1349 
(Conspiracy to Commit Wire Fraud) 
NMT 20 Years Imprisonment 
NMT $250,000 Fine 
NLT 3 Years Supervised Release 
Class C Felony 
COUNTS TWO - SEVEN: 
18 U.S.C. § 1343 
(Wire Fraud) 
NMT 20 Years Imprisonment 
NMT $250,000 Fine 
NLT 3 Years Supervised Release 
Class C Felony 
ALLEGATION OF CRIMINAL 
FORFEITURE 
18 U.S.C. § 981(a)(1)(C) 
28 U.S.C. § 2461 
$100 Mandatory Special Assessment Each 
Count 
23-00233-01/06-CR-W-DGK
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I N D I C T M E N T 
 
THE GRAND JURY CHARGES THAT: 
 
COUNT ONE 
 
At all times material to this Indictment: 
Introduction 
1. 
Beginning no later than on or about March 2021, and continuing 
until at least January 
2022, 
in 
Jackson 
County, 
within 
the 
Western 
District of 
Missouri and elsewhere, 
RENETTA 
GOLDEN-LARIMORE 
(GOLDEN-LARIMORE); 
CAMONTE HENDERSON; 
TAJONA 
MANNING; 
TASHAWN 
MAYFIELD; 
QUINNIECE SMITH and DANNISHA TAYLOR, defendants herein, conspired, confederated 
and agreed with each other and persons known and unknown to the grand jury, to electronically 
submit false and fraudulent applications for Paycheck Protection Program (PPP) loans affecting 
interstate commerce. The scheme caused over $240,000 in fraudulent PPP loans to be issued to 
ineligible borrowers, some of which were forgiven even though the funds were not used for the 
purposes specified in the PPP. 
2. 
Defendant GOLDEN-LARIMORE, a resident of Kansas City, Missouri, prepared 
and filed fraudulent PPP loan applications on behalf of other persons. Generally, she charged fees 
between $2,000 and $7,000 for her assistance in filing false and fraudulent PPP loans. GOLDEN-
LARIMORE would create counterfeit IRS Forms Schedule C for nonexistent businesses and with 
inflated income for existing businesses in order to qualify the borrower for a PPP loan. GOLDEN-
LARIMORE submitted and caused to be submitted false and fraudulent PPP loan applications and 
counterfeit IRS Forms Schedule C to the Small Business Administration (SBA) and lenders 
outside the State of Missouri. 
 
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I. 
THE PAYCHECK PROTECTION PROGRAM 
 
3. 
On March 27, 2020, the President signed into law the Coronavirus Aid,  Relief, and 
Economic Security Act (“The Cares Act”), an economic stimulus bill that, among  other things, 
provided emergency assistance to small business owners, including agricultural businesses, 
and nonprofit organizations in all U.S. states, Washington D.C., and territories affected by 
the COVID-19 pandemic. One source of relief provided by the CARES Act was the 
authorization of up to $349 billion in forgivable loans to small businesses for job retention and 
certain other expenses, through a program referred to as the Paycheck Protection Program (“PPP”). 
Additional PPP funding was authorized in legislation enacted on or about December 27, 2020, and 
March 11, 2021. 
4. 
As discussed more fully below, the PPP program, which is operated by the 
Small Business Administration (“SBA”) provided small businesses with funding to meet specific 
business obligations, including payroll and rent. The PPP permitted participating third-party 
lenders to approve and disburse SBA-backed PPP loans to cover payroll, fixed debts, utilities, 
rent/mortgage, accounts payable and other bills incurred by qualifying businesses during, and 
resulting from, the COVID-19 pandemic. PPP loans are fully guaranteed by the SBA. In the event 
of default, SBA will fully satisfy the lender for any balance remaining on the loan. Further, SBA 
will forgive any loan up to 100 percent if the borrower establishes it utilized 60 percent of the loan 
on payroll costs in the 24-week period post-disbursement, with the remaining 40 percent going 
toward covered mortgage interest payments, covered rent payments, covered utilities, covered 
operations expenditures, covered property damage costs, covered supplier costs, and covered 
worker protection expenditures. Whatever portion is not forgiven is serviced as a loan. 
 
 
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5. 
The SBA promulgated regulations concerning eligibility for a PPP loan. To obtain 
a PPP loan, a qualifying business was required to submit a PPP loan application, which 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, including that the business 
was in operation on February 15, 2020 and either had employees for whom  it paid salaries and 
payroll taxes or paid independent contractors, as reported on a “Form 1099-MISC.” Specifically, 
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. 
6. 
Individuals who operated a business under a “sole proprietorship” business 
structure were also eligible for a PPP loan. To qualify for a PPP loan, individuals had to report and 
document their income and expenses from the sole proprietorship, as typically reported to the 
Internal Revenue Service on a “Form 1040, Schedule C,” for a given tax year. As with other 
PPP loans, this information and supporting documentation was used to calculate the amount of 
money the individual was entitled to receive under the PPP. The maximum loan amount for a sole 
proprietor with no employees was $20,833. 
7. 
A PPP loan application was processed by the third-party participating lender with 
whom the application was filed. If a PPP loan application was approved, the participating lender 
would fund the PPP loan; in order to encourage PPP loans to  be issued, the loan was guaranteed 
by the SBA. Data from the application, including information from 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. 
 
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8. 
The proceeds of a PPP loan could be used only for certain specified items, such as 
payroll costs, costs related to the continuation of group health care benefits, or mortgage interest 
payments. The proceeds of a PPP loan were not permitted to be used by the borrowers to purchase 
consumer goods, automobiles, personal residences, clothing, jewelry, to pay the borrower’s 
personal federal income taxes, or to fund the borrower’s ordinary day-to-day living expenses 
unrelated to the specified authorized expenses. 
9. 
The following lenders funded the PPP loans: 
 
Prestamos CDFI, LLC (Prestamos) was a Community Development Financial Institution 
(CDFI) headquartered in Arizona; 
 
Capital Plus Financial, LLC was a CDFI headquartered in Bedford, Texas. 
 
 
COUNT ONE 
 
The Scheme 
 
10. 
The allegations set forth in paragraphs 1 through 9 are hereby incorporated in full. 
11. 
Beginning on or about March 2021, and continuing through on or 
about January 2022, in Jackson County, within the Western District of Missouri and 
elsewhere, the defendants RENETTA GOLDEN-LARIMORE; CAMONTE HENDERSON; 
TAJONA MANNING; 
TASHAWN 
MAYFIELD; 
QUINNIECE 
SMITH; and 
DANNISHA TAYLOR did knowingly combine, conspire, confederate, and agree with each other 
and with persons known and unknown to the Grand Jury, to devise and intend to devise a scheme 
and artifice to defraud, and to obtain money and property, by means of materially false and 
fraudulent pretenses, representations, and promises, and by omission of material facts, well 
knowing and having reason to know that said pretenses were and would be false and fraudulent 
when made and caused to made and that said omissions were and would be material, and in 
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furtherance thereof transmitted and caused to be transmitted interstate wire communications, 
contrary to Title 18, United States Code, Section 1343. 
Manner and Means: 
12. 
GOLDEN-LARIMORE created PPP loan applications for each of the 
co-conspirators in exchange for a payment from the loan proceeds. The applications falsely stated 
either the existence of a sole proprietorship prior to the pandemic or greatly inflated the revenues 
of any “businesses” that did exist in 2019. 
13. 
GOLDEN-LARIMORE made and forged fictitious IRS Forms Schedule C to 
support the fraudulent PPP loan applications that would be submitted to various third-party lenders 
designated by the SBA to participate in the PPP. These IRS Forms Schedule C falsely stated that 
the person in whose name the loan was submitted had operated a sole proprietorship in 2019 or 
2020. The IRS Forms Schedule C included false statements of income and expenses attributed to 
the business in whose name the PPP loan application was submitted. The PPP loan applications 
also certified that the information provided in the application and in supporting documents was 
true and accurate in all respects. 
14. 
GOLDEN-LARIMORE submitted the PPP loan applications on behalf of each of 
the co-conspirators. GOLDEN-LARIMORE submitted the applications from a computer using 
internet service located in Kansas City, Missouri. GOLDEN-LARIMORE often used the internet 
access on her telephone to monitor the progress in the processing of the loan applications.  
15. 
Once 
the 
PPP 
loans 
were 
funded, 
the 
co-conspirators 
would pay 
GOLDEN-LARIMORE between $2,000 and $7,000 for making and submitting the false loan 
applications. 
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16. 
On or about the dates listed below, GOLDEN-LARIMORE electronically 
created loan accounts, submitted false PPP loan applications through Blue Acorn, or checked the 
status of the loans to the SBA’s servers in Oregon or to the lenders in the states listed below: 
 
DATE 
BORROWER 
IP 
ADDRESS 
FINANCE COMPANY 
& LOCATION 
Amount 
of PPP 
Loan 
a. 
03/20/2021 CAMONTE 
HENDERSON 
75.81.141.44 Capital Plus Financial, 
LLC, Texas 
$20,832 
b. 
03/29/2021 TAJONA MANNING 
75.81.141.44 Capital Plus Financial, 
LLC, Texas 
$20,832 
c. 
04/02/2021  TASHAWN 
MAYFIELD 
75.81.141.44 Capital Plus Financial, 
LLC, Texas 
$20,832 
d. 
03/20/2021 QUINNIECE SMITH 
75.81.141.44 Capital Plus Financial, 
LLC, Texas 
$20,832 
e. 
05/20/2021 QUINNIECE SMITH 
75.81.141.44 Prestamos – Arizona 
$20,832 
f. 
04/11/2021 DANNISHA TAYLOR 
75.81.141.44 Capital Plus Financial, 
LLC, Texas 
$20,832 
 
All in violation of the provisions of Title 18, United States Code, Section 1349. 
COUNTS TWO - SEVEN 
17. 
Paragraphs 1 through 16 of the Indictment are hereby realleged and incorporated 
into Counts Two through Seven. 
COUNT TWO 
18. 
On or about March 20, 2021, defendant RENETTA GOLDEN-LARIMORE, aided 
and abetted by defendant, CAMONTE HENDERSON, crated an application to Blue Acorn to 
apply for a PPP loan under the CARES Act for HENDERSON’s business - “Henderson’s 
Landscapers”. 
 
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19. 
The application and supporting documents were submitted on April 5, 2021, and 
stated that the defendant CAMONTE HENDERSON was a sole proprietor of a business which 
had gross receipts or sales of $225,001 and a profit of $219,301. As part of the application, a 
2020 tax return for the defendant CAMONTE HENDERSON was submitted listing the same gross 
receipts and profit of on Form Schedule C. 
20. 
In fact, the defendant CAMONTE HENDERSON did not have a business in 
2019 with those gross receipts and profit. CAMONTE HENDERSON’s 2019 tax return listed 
$9,153 in wages and no other income. 
21. 
On or about the date set forth below, in Kansas City, Missouri, in the Western 
District of Missouri, the defendant, RENETTA GOLDEN-LARIMORE, aided and abetted by 
defendant CAMONTE HENDERSON, having devised and intended to devise a scheme to obtain 
money by means of materially false and fraudulent pretenses, representations, and promises, for 
the purpose of executing the scheme described above, caused to be transmitted by means of wire 
communication in interstate commerce the signals and sounds described below:  
Count 
Date 
Wire From 
To 
Amount 
2 
04/27/2021 
Capital Plus Financial First Federal Bank of 
Kansas City 
$20,832 
 
All in violation of the provisions of Title 18, United States Code, Section 1343. 
 
COUNT THREE 
22. 
On or about March 29, 2021, defendant RENETTA GOLDEN-LARIMORE, aided 
and abetted by defendant TAJONA MANNING, completed and sent an application and supporting 
documents to Blue Acorn to apply for a PPP loan under the CARES Act for her business. 
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23. 
The 
application 
and 
supporting 
documents 
stated 
that 
the defendant 
TAJONA MANNING was a sole proprietor of a business established July 2, 2018, and that had 
gross receipts of $144,080 and net income of $99,982.  As part of the application, a 2019 Form 
Schedule C was submitted listing gross receipts of $225,001 and a profit of $101,133. 
24. 
In fact, the defendant TAJONA MANNING did not have a business in 2019 
with those gross receipts and profit. TAJONA MANNING’s personal 2019 tax return reported 
$28,852 in wages and no other income. 
25. 
On or about the date set forth below, in Kansas City, Missouri, in the 
Western District of Missouri, the defendant, RENETTA GOLDEN-LARIMORE, aided and 
abetted by defendant TAJONA MANNING, having devised and intended to devise a scheme to 
obtain money by means of materially false and fraudulent pretenses, representations, and promises, 
for the purpose of executing the scheme described above, caused to be transmitted by means of 
wire communication in interstate commerce the signals and sounds described below: 
Count 
Date 
Wire From 
To 
Amount 
3 
04/29/2021  
Capital Plus 
Community American 
Credit Union 
$20,832 
 
Contrary to the provisions of Title 18, United States Code, Section 1343. 
 
COUNT FOUR 
26. 
On or about April 2, 2021, defendant RENETTA GOLDEN-LARIMORE, aided 
and abetted by defendant TASHAWN MAYFIELD, completed and sent an application and 
supporting documents to Blue Acorn to apply for a PPP loan under the CARES Act for 
her business. 
 
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27. 
The 
application 
and 
supporting 
documents 
stated 
that 
the defendant 
TASHAWN MAYFIELD was a sole proprietor of a business established February 4, 2019, and 
that had gross receipts of $141,080 and net income of $135,887. As part of the application, a 2019 
Form Schedule C was submitted listing gross receipts of $144,080 and a net income of $135,887. 
28. 
In fact, the defendant TASHAWN MAYFIELD did not have a business in 2019 
with those gross receipts and profit. TASHAWN MAYFIELD’s personal 2019 tax return listed 
adjusted gross income of $43,459. 
29. 
On or about the date set forth below, in Kansas City, Missouri, in the 
Western District of Missouri, the defendant, RENETTA GOLDEN-LARIMORE, aided and 
abetted by defendant TASHAWN MAYFIELD, having devised and intended to devise a 
scheme to obtain money by means of materially false and fraudulent pretenses, 
representations, and promises, for the purpose of executing the scheme described above, caused 
to be transmitted by means of wire communication in interstate commerce the signals and sounds 
described below:  
Count 
Date 
Wire From 
To 
Amount 
4 
04/29/21 
Capital Plus Financial Bank Midwest 
$20,832 
 
Contrary to the provisions of Title 18, United States Code, Section 1343. 
COUNT FIVE 
30. 
On or about March 20, 2021, defendant RENETTA GOLDEN-LARIMORE, aided 
and abetted by defendant QUINNIECE SMITH, completed and sent an application and supporting 
documents to Blue Acorn to apply for a PPP loan under the CARES Act for her business 
- beautician services. 
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31. 
The 
application 
and 
supporting 
documents 
stated 
that 
the defendant 
QUINNIECE SMITH was a sole proprietor of a business established March 1, 2018, and that had 
gross receipts of $225,001 and net income of $219,301. As part of the application, a 2020 Form 
Schedule C was submitted listing the same amounts. 
32. 
In fact, the defendant QUINNIECE SMITH did not have a business in 2020 with 
those gross receipts and profit. QUINNIECE SMITH did not file a tax return in 2020. 
33. 
On or about the date set forth below, in Kansas City, Missouri, in the Western 
District of Missouri, the defendant, RENETTA GOLDEN-LARIMORE, aided and abetted by 
defendant QUINNIECE SMITH, having devised and intended to devise a scheme to obtain 
money by means of materially false and fraudulent pretenses, representations, and promises, for 
the purpose of executing the scheme described above, caused to be transmitted by means of wire 
communication in interstate commerce the signals and sounds described below: 
Count 
Date 
Wire From 
To 
Amount 
5 
04/01/2021 
Capital Plus Financial JP Morgan Chase Bank 
$20,832 
 
Contrary to the provisions of Title 18, United States Code, Section 1343. 
COUNT SIX 
34. 
On or about May 20, 2021, defendant RENETTA GOLDEN-LARIMORE, aided 
and abetted by defendant QUINNIECE SMITH, completed and sent an application and supporting 
documents to Blue Acorn to apply for a PPP loan under the CARES Act for her business. 
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35. 
The 
application 
and 
supporting 
documents 
stated 
that 
the defendant 
QUINNIECE SMITH was a sole proprietor of a business that in 2019 had gross receipts of 
$144,080. As part of the application, a 2020 tax return with a Form Schedule C was submitted 
listing gross receipts of $144, 080 and a net profit of $99,982. 
36. 
In fact, the defendant QUINNIECE SMITH did not have a business in 2020 with 
those gross receipts and profit. QUINNIECE SMITH’s 2019 tax return listed a business loss of 
$5,104 and she did not file a personal 2020 tax return. 
37. 
On or about the date set forth below, in Kansas City, Missouri, in the Western 
District of Missouri, the defendant, RENETTA GOLDEN-LARIMORE, aided and abetted by 
defendant QUINNIECE SMITH, having devised and intended to devise a scheme to obtain 
money by means of materially false and fraudulent pretenses, representations, and promises, for 
the purpose of executing the scheme described above, caused to be transmitted by means of wire 
communication in interstate commerce the signals and sounds described below: 
Count 
Date 
Wire From 
To 
Amount 
6 
06/11/2021 
Prestamos 
Navy Federal Credit Union 
$20,832 
 
Contrary to the provisions of Title 18, United States Code, Section 1343. 
COUNT SEVEN 
38. 
On or about April 18, 2021, defendant RENETTA GOLDEN-LARIMORE, aided 
and abetted by defendant DANNISHA TAYLOR, completed and sent an application and 
supporting documents to Blue Acorn to apply for a PPP loan under the CARES Act for her 
business. 
 
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39. 
The 
application 
and 
supporting 
documents 
stated 
that 
the defendant 
DANNISHA TAYLOR was a sole proprietor of a business established February 18, 2018, and that 
had gross receipts of $144,080 and net income of $99,982. As part of the application, a 2019 tax 
return with a Form Schedule C was submitted the same amounts. 
40. 
In fact, the defendant DANNISHA TAYLOR did not have a business in 2019 with 
those gross receipts and profit. DANNISHA TAYLOR’s 2019 tax return listed adjusted gross 
income of $7,332. 
41. 
On or about the date set forth below, in Kansas City, Missouri, in the Western 
District of Missouri, the defendant, RENETTA GOLDEN-LARIMORE, aided and abetted by 
defendant DANNISHA TAYLOR, having devised and intended to devise a scheme to obtain 
money by means of materially false and fraudulent pretenses, representations, and promises, for 
the purpose of executing the scheme described above, caused to be transmitted by means of wire 
communication in interstate commerce the signals and sounds described below: 
Count 
Date 
Wire From 
To 
Amount 
7 
05/14/2021 
Capital Plus 
Regions Bank 
$20,832 
 
Contrary to the provisions of Title 18, United States Code, Section 1343. 
FORFEITURE ALLEGATION 
 
42. 
The statements and allegations contained in counts one through seven of this 
Indictment are realleged and incorporated by reference for purposes of alleging forfeiture to the 
United States, pursuant to provisions of Title 18, United States Code, Section 981(a)(1)(C) and 
Title 28, United States Code, Section 2461. 
 
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43. 
As a result of the offenses alleged in counts one through six of the Indictment, 
defendants CAMONTE HENDERSON; TAJONA MANNING; TASHAWN MAYFIELD; 
QUINNICE SMITH; and DANNISHA TAYLOR shall forfeit all property real and personal, 
constituting, or derived from, proceeds traceable to the offense, directly or indirectly, as a result of 
the violations of law set out in Counts 1 through 7 of this Indictment, including, but not limited to, 
the following property: a separate money judgment as to each individually named defendant in this 
allegation in the amount of at least $20,832. 
Substitute Assets 
44. 
If any of the property described in the above paragraph, as a result of any act or 
omission of the defendants, 
(A) 
cannot be located upon the exercise of due diligence; 
 
(B) 
has been transferred to, sold to, or deposited with a third person; 
 
(C) 
has been placed beyond the jurisdiction of the Court; 
 
(D) 
has been substantially diminished in value; and/or 
 
(E) 
has been commingled with other property that cannot be subdivided without 
difficulty; 
 
it is the intent of the United States, pursuant to Title 21, United States Code, Section 853(p), which 
is incorporated by Title 18, United States Code, Section 982(b)(1) and Title 28, United States Code, 
Section 2461(c), to seek forfeiture of any other property of the defendants up to the value of the 
forfeitable property. 
A TRUE BILL. 
 
10/18/2023 
 
 
 
 
 
/s/ Kimberley Deardorff  
 
 
 
DATE 
FOREPERSON OF THE GRAND JURY 
 
/s/ Paul Becker  
 
 
 
 
Paul S. Becker 
Assistant United States Attorney 
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