Criminal Complaint — United States v. Johansson (C.D. Cal.)

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U.S. District Court, Central District of California · No. 5:21-mj-00461-DUTY · Doc. 1 · 2021-07-02 · Docket on CourtListener

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AUSA: Matthew O’Brien, ext. 8644 
AO 91 (Rev. 11/11)  Criminal Complaint (Rev. by USAO on 3/12/20) 
  ܆  Original     ܆ Duplicate Original  
UNITED STATES DISTRICT COURT 
for the 
Central District of California 
United States of America 
v. 
CARL BRADLEY JOHANSSON, 
Defendant(s) 
Case No.  
CRIMINAL COMPLAINT BY TELEPHONE  
OR OTHER RELIABLE ELECTRONIC MEANS 
I, the complainant in this case, state that the following is true to the best of my knowledge and belief.  
On or about the dates of April 24, 2020 through March 24, 2021, in the county of Riverside in the Central 
District of California, and elsewhere, the defendant violated: 
Code Section 
Offense Description 
18 U.S.C. §§ 1344(2), 2(b), 1349 
Bank Fraud, Causing An Act To Be 
Done, Conspiracy To Commit Bank 
Fraud 
This criminal complaint is based on these facts: 
Please see attached affidavit. 
_ Continued on the attached sheet. 
Complainant’s signature 
Daniel DrHyer, Special Agent 
Printed name and title 
Attested to by the applicant in accordance with the requirements of Fed. R. Crim. P. 4.1 by telephone. 
Date: 
City and state: Los Angeles, California 
Judge’s signature 
Hon. Alexander F. MacKinnon, U.S. Magistrate Judge 
Printed name and title 
07/01/2021
jbb
5:21-mj-00461
jbb
LODGED
CLERK, U.S. DISTRICT COURT
CENTRAL DISTRICT OF CALIFORNIA
BY: ___________________ DEPUTY
07/01/2021
7/2/2021
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/ S /
Jul -2 2021
ib

ATTACHMENT TO COMPLAINT 
Offense Descriptions: 
[18 U.S.C. §§ 1344(2), 2(b)] 
On or about January 19, 2021, in Riverside County, within the Central District of 
California, and elsewhere, defendant CARL BRADLEY JOHANSSON, also known as (“aka”) 
“Brad Johansson,” aka “Brad Johnson,” aka “Carl Johnson,” “C. Brad Johanson,” aka “Jay 
Johnson,” aka “Keith Golatta, ” aka “Keith Golwick” (“JOHANSSON”), acting with the intent to 
defraud, knowingly executed and attempted to execute a scheme to defraud a federally-insured 
financial institution, as to material matters, and to obtain moneys and funds owned by and in the 
custody and control of the Bank by means of material false and fraudulent pretenses, 
representations, and promises, and the concealment of material facts.  To execute the fraudulent 
scheme, defendant JOHANSSON submitted, and caused to be submitted, a Paycheck Protection 
Program (“PPP”) loan forgiveness application for his company Western Distribution, LLC in the 
amount of $436,390, which falsely claimed that Western Distribution, LLC employed certain 
workers, and used its PPP loan to pay salaries for those certain workers, when those workers 
were not in fact employed by Western Distribution, LLC and had not been paid by Western 
Distribution, LLC using its PPP funds.    
[18 U.S.C. §1349] 
From on or about April 24, 2020 through March 24, 2021, in Riverside County, within 
the Central District of California, and elsewhere, defendant JOHANSSON, together with others 
known and unknown, conspired to commit bank fraud, in violation of Title 18, United States 
Code, Section 1344.  The objects of the conspiracy were carried out, and to be carried out, in 
substance as follows: 
In April 2020, defendant JOHANSSON, and his co-conspirators, would cause Western 
Distribution, LLC to apply for and obtain a PPP loan in the amount of $436,390, yet fail to 
disclose on the PPP loan application that Western Distribution, LLC shared common 
management (i.e., defendant JOHANSSON) with other businesses, and falsely claim on the PPP 
loan application that Western Distribution, LLC would spend the loan proceeds in accordance 
with the PPP rules.  In September 2020, defendant JOHANSSON, and his co-conspirators, 
would cause 21 individuals to be placed on Western Distribution, LLC’s payroll, even though 
those 21 individuals did not work for Western Distribution, LLC and their salaries were being 
paid by a separate company.  Defendant JOHANSSON, and his co-conspirators, would cause 
Western Distribution, LLC to submit a PPP loan forgiveness application in January 2021 that 
falsely claimed that the 21 individuals worked for Western Distribution, LLC so that Western 
Distribution, LLC could meet the PPP loan-forgiveness eligibility requirement that at least sixty 
percent of a company’s PPP loan be spent on payroll.  In March 2021, defendant JOHANSSON, 
and his co-conspirators, would cause Western Distribution, LLC to apply for a second PPP loan 
in the amount of $231,527, using the same fraudulent scheme whereby they represented – falsely 
– the number of employees who worked for Western Distribution, LLC in order to obtain a 
larger loan.  
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Contents 
I. 
INTRODUCTION..........................................1 
II. 
SUMMARY OF PROBABLE CAUSE.............................2 
III. THE PAYCHECK PROTECTION PROGRAM.......................6 
IV. 
STATEMENT OF PROBABLE CAUSE...........................8 
A. 
JOHANSSON’s History of Concealing His Involvement 
in His Trucking Companies........................8 
B. 
JOHANSSON’s Formation of Western Distribution, 
LLC in Early 2019...............................15 
C. 
JOHANSSON’s Fraudulent Use of Advanced Fuel 
Delivery’s Name and DOT Registration Number.....17 
D. 
JOHANSSON’s Decision to Make Western 
Distribution, LLC a Defunct Entity as of 
September 2019..................................19 
E. 
JOHANSSON’s Control of Western Distribution, LLC
................................................22 
F. 
Western Distribution, LLC’s First PPP Loan 
Application in April 2020.......................23 
G. 
Company A’s PPP Loan Application in April 2020..26 
H. 
Western Distribution, LLC’s Expenditure of Its 
First PPP Loan..................................29 
I. 
The Transfer of Company A’s Employees to Western 
Distribution, LLC’s Payroll Account.............32 
J. 
Western Distribution, LLC’s Fraudulent PPP Loan 
Forgiveness Application.........................35 
K. 
Western Distribution, LLC’s Fraudulent Second PPP 
Loan Application in March 2021..................38 
L. 
JOHANSSON’s Concurrent Fraud on the Department of 
Transportation..................................41 
V. 
CONCLUSION...........................................45 
 
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AFFIDAVIT 
I, DANIEL DREYER, being duly sworn, declare and state as 
follows:  
I. 
INTRODUCTION 
1. 
I am a Special Agent (“SA”) with Internal Revenue 
Service - Criminal Investigations (“IRS-CI”) in the Los 
Angeles Field Office.  I have been a Special Agent since July 
2017.  I am presently assigned to a group located in Santa 
Ana, California.  I attended college at University of 
California, Santa Barbara, where I obtained a bachelor’s 
degree in Business Economics with Emphasis in Accounting in 
2002.  After graduation, I worked in the field of public 
accounting for approximately 12 years where I obtained the 
job title of Senior Audit Manager.  In 2008, I became 
licensed as a certified public accountant (“CPA”) in the 
State of California and I have maintained the requirements 
for this license since that date.  As an audit manager, I 
oversaw complex audit engagements, including the analysis of 
risks associated with financial fraud.  Additionally, I 
focused on methods and types of financial fraud and what 
measures can be used to detect and deter such activity.  I 
attended training for approximately six months at the Federal 
Law Enforcement Training Center in Glynco, Georgia, where I 
graduated in February 2018.  During my training, I learned 
investigative techniques used by the Internal Revenue Service 
(“IRS”) to investigate the criminal violations found in 
Titles 18, 26, and 31 of the United States Code that fall 
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under IRS-CI’s investigative jurisdiction.  I have assisted 
in the execution and planning of search warrants related to a 
number of violations.  As a Special Agent, I have 
investigated money laundering, tax fraud, and Bank Secrecy 
Act violations.  As a result of my training and experience, I 
am familiar with the methods used by criminals to commit 
these types of offenses. 
2. 
I make this affidavit in support of an application for 
an arrest warrant for Carl Bradley Johansson (“JOHANSSON”) for 
violations of 18 U.S.C. §§ 1344(2) and 2(b) (bank fraud and 
causing an act to be done) and 18 U.S.C. § 1349 (conspiracy to 
commit bank fraud).  
3. 
The facts set forth in this affidavit are based upon 
my personal observations, my training and experience, and 
information obtained from other agents and witnesses.  This 
affidavit is intended to show merely that there is sufficient 
probable cause for the requested warrant and does not purport to 
set forth all of my knowledge of or investigation into this 
matter.  Unless specifically indicated otherwise, all 
conversations and statements described in this affidavit are 
related in substance and in part only. 
II. 
SUMMARY OF PROBABLE CAUSE 
5. 
In April 2018, a federal grand jury indicted 
JOHANSSON, two of his employees, and two of his trucking 
companies for conspiracy, welding without required 
certifications, and false statements (C.D. Cal. Case No. 5:18-
CR-114-VAP) (the “Pending Criminal Case”).  A first superseding 
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indictment, which added six counts against JOHANSSON for tax 
evasion, was filed on or about November 14, 2018, and a second 
superseding indictment was filed on or about November 20, 2019.  
JOHANSSON and the other defendants pleaded not guilty to all 
charges.  A trial is scheduled for September 14, 2021 before the 
Honorable Virginia A. Phillips.  
6. 
In the Pending Criminal Case, the government alleges, 
inter alia, that JOHANSSON owned and controlled a series of 
trucking companies yet kept his name off of his companies’ books 
in order to (1) conceal his own involvement in the companies 
from regulators investigating welding explosions at the 
companies, and (2) avoid paying federal income taxes on his 
considerable income from the companies.  (In 1999, JOHANSSON 
pled guilty to a similar scheme resulting from a different 
welder’s death; JOHANSSON was sentenced to 15 months in prison 
(C.D. Cal. Case No. 98-CR-674-RAP).)    
7. 
In March 2019, while on pre-trial release in the 
Pending Criminal Case, JOHANSSON set up yet another trucking 
company, Western Distribution, LLC, and registered it as an LLC 
in Wyoming.  Western Distribution was based in Buena Park, 
California (it is now based in Ontario, California), and focuses 
on the transportation of jet fuel.  In September 2019, JOHANSSON 
converted Western Distribution, LLC into Advanced Distribution, 
Inc. and then converted Advanced Distribution, Inc. into Western 
Distribution, Inc.  From that point forward, Western 
Distribution, LLC no longer existed as a legal entity; 
nonetheless, JOHANSSON continued operating the LLC as if nothing 
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had changed. 
8. 
In early 2020, when the COVID-19 pandemic hit the 
United States, the federal government responded, as relevant 
here, by setting up the Paycheck Protection Program (“PPP”), 
whereby eligible businesses could apply to the Small Business 
Administration (“SBA”) for low-interest (and potentially 
forgivable) loans to obtain money that was to be used primarily 
to pay their employees.  The first page of the PPP loan 
application asked applicants, inter alia, if they or their 
owners were currently under indictment, and if they shared 
common management with any other businesses. 
9. 
On or about April 24, 2020, under JOHANSSON’s 
direction, Western Distribution, LLC applied to a federally 
insured bank (the “Bank”) for a PPP loan in the amount of 
$436,390, even though the LLC no longer existed.  JOHANSSON 
listed his son, Co-conspirator #1, as the owner of Western 
Distribution, LLC on the application, enabling him to answer the 
“are your owners under indictment” question in the negative.  
Despite the fact that JOHANSSON controlled and managed Western 
Distribution, LLC at the same time that he controlled and 
managed other companies -- including Wholesale Distribution, 
Inc. (one of JOHANSSON’s co-defendants in the Pending Criminal 
Case), and “Company A” -- the application claimed that Western 
Distribution, LLC had no common management with any other 
companies.  The application was approved, and Western 
Distribution, LLC received a PPP loan in the amount of $436,390. 
10. 
“Company A” is another trucking company controlled by 
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JOHANNSON.  It is based in Gustine, California and focuses on 
the transportation of agricultural materials.  On or about April 
15, 2020, under JOHANSSON’s direction, Company A applied to 
another federally insured bank for its own PPP loan in the 
amount of $286,505.  JOHANSSON had his 85-year old mother listed 
as Company A’s owner on Company A’s PPP application, enabling 
him to again answer the “are your owners under indictment” 
question in the negative.  Like Western Distribution, LLC’s 
application, Company A’s application claimed that Company A had 
no common management with any other businesses.  Company A’s 
application was approved, and the company received a PPP loan in 
the amount of $286,500.  
11. 
Under JOHANSSON’s direction, Western Distribution, LLC 
immediately spent its PPP funds in May and June 2020, in large 
part on expenses unrelated to its payroll.  Rather than using 
the funds to keep his employees at Western Distribution, LLC on 
payroll, JOHANSSON laid off most of the company’s employees.  
Later in 2020, when Western Distribution, LLC’s business picked 
back up, JOHANSSON rehired many of the same employees.   
12. 
In order to create the impression that Western 
Distribution, LLC had spent more of its PPP loan on its payroll 
than it really did, in September 2020 JOHANSSON moved 21 of 
Company A’s employees onto Western Distribution, LLC’s payroll.  
This substantially increased Western Distribution, LLC’s 
purported payroll, and made it look like Western Distribution, 
LLC was spending much more of its money on payroll than it 
really was, just before its 24-week window for spending the PPP 
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funds closed.  As a result of this ruse, Western Distribution, 
LLC could claim -- falsely -- on its PPP loan forgiveness 
application to the Bank in January 2021 that the company had met 
the requisite threshold of spending at least sixty percent of 
its PPP loan on payroll.  In fact, as JOHANNSON was aware, 
Western Distribution, LLC had spent much of the PPP loan on 
other expenses in May and June 2020 and effectively laid off 
most of its employees.  As JOHANSSON was also aware, none of 
Company A’s employees ever actually worked for Western 
Distribution, LLC in 2020; JOHANSSON had transferred them onto 
Western Distribution, LLC’s payroll solely as part of a shell 
game to conceal his scheme from the Bank and federal regulators.  
13. 
In March 2021, JOHANSSON caused Western Distribution, 
LLC to repeat the same fraudulent representations concerning its 
employee lists and payroll numbers when the company submitted a 
second PPP loan application, for $231,527, to the Bank.  
III. THE PAYCHECK PROTECTION PROGRAM 
14. 
The CARES Act is a federal law enacted in around March 
2020 and was 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 up to $349 
billion in forgivable loans to small businesses for job 
retention and certain other expenses, through a program referred 
to as the PPP.  In approximately April 2020, Congress authorized 
over $300 billion in additional PPP funding. 
15. 
In order to obtain a PPP loan, a qualifying business 
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must submit a PPP loan application, which is signed by an 
authorized representative of the business.  The PPP loan 
application requires 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.  One such certification requires the 
applicant (through its authorized representative) to affirm that 
“[t]he [PPP loan] funds will be used to retain workers and 
maintain payroll or make mortgage payments, lease payments, and 
utility payments; I understand that if the funds are used for 
unauthorized purposes, the federal government may pursue 
criminal fraud charges.”  In the PPP loan application, the small 
business (through its authorized representative) must state, 
among other things, its: (a) average monthly payroll expenses; 
and (b) number of employees.  These figures are used to 
calculate the amount of money the small business is eligible to 
receive under the PPP.  In addition, businesses applying for a 
PPP loan must provide documentation showing their payroll 
expenses.  These figures are used to calculate the amount of 
money the small business is eligible to receive under the PPP. 
In addition, businesses applying for a PPP loan must provide 
documentation showing their payroll expenses. 
16. 
PPP loan proceeds must be used by the business on 
certain permissible expenses -- payroll costs, interest on 
mortgages, rent, and utilities.  The PPP allows the interest and 
principal on the PPP loan to be entirely forgiven if the 
business spends the loan proceeds on these expense items within 
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a designated period of time (usually 24 weeks after receiving 
the proceeds) and uses at least sixty percent of the PPP loan 
proceeds on payroll expenses. 
17. 
The PPP loan application includes eligibility 
questions pertaining to current and past criminal histories of 
any and all individuals owning twenty percent or more of the 
applicant company.  These questions are further certified by the 
signer with the understanding that any material false statements 
are punishable under specified laws and subject to both fines 
and imprisonment.  The application states that any recent felony 
conviction or current indictment of an owner of twenty percent 
or more of an applicant makes the applicant ineligible for PPP 
funding. 
IV. 
STATEMENT OF PROBABLE CAUSE 
Based upon my review of investigative reports and notes, 
bank records, witness statements, my discussions with other law 
enforcement officers working on this investigation, and other 
evidence, I learned the following: 
A. 
JOHANSSON’s History of Concealing His Involvement in 
His Trucking Companies 
1. 
National Distribution Services, Inc.   
23. 
On or about September 27, 1993, L.Q., a welder at 
Atlas Carrier, Inc. (“Atlas”), located in Montebello, 
California, was killed while working inside a cargo tanker when 
his welding torch ignited fumes.  Atlas, a hazardous-materials 
transportation company, was not registered with the United 
States Department of Transportation (“DOT”) to perform the 
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repair of cargo tanks and did not have the “R” Stamp 
certification required to carry out such welding.  JOHANSSON was 
the president and owner of Atlas, which did business under 
several names including Ash Transportation, Inc., Petroleum 
Delivery Services, and Ash Incorporated. 
24. 
As result of the investigation into L.Q.’s death, in 
around June 1998 JOHANSSON and an Atlas manager were indicted by 
a federal grand jury on five counts, specifically, one count of 
violating 18 U.S.C. § 371 and four counts of violating 49 U.S.C. 
§ 5124 (welding without an “R” stamp).  See United States v. 
Carl Bradley Johansson, Case No. 98-CR-674-RAP (C.D. Cal.).  
JOHANSSON pled guilty and was sentenced in 2000 to a term of 15 
months’ imprisonment followed by two years of supervised 
release.  Upon his release from prison, JOHANSSON returned to 
managing his trucking companies.   
25. 
In 2007, the federal government sued JOHANSSON for 
employment taxes owed by his former company, Atlas Bulk, Inc. 
(C.D. Cal. Case No. 07-CV-659-AHS).  The district court entered 
judgment against JOHANSSON in 2008 for $923,440.  After the 
judgment was entered, JOHANSSON filed no personal tax returns 
(and paid no personal income taxes) until after he was indicted 
again in 2018, despite earning over a million dollars in 
unreported income from his trucking companies during that period 
and despite enjoying a lifestyle that included, for example, 
living in a 16,000-square-foot mansion in Corona for which he 
paid approximately $16,000 each month in rent from 2012 to 2018. 
26. 
By no later 2012, JOHANSSON had taken control of 
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National Distribution Services, Inc. (“National”), a hazardous-
materials transportation company based in Corona.  Bank records 
and employee interviews confirm that JOHANSSON controlled all 
aspects of National’s business, from operations to banking.  Yet 
as a result of the tax case and increasing regulatory scrutiny 
regarding his trucking companies’ safety, JOHANSSON went to 
great lengths to conceal his involvement in National.  For 
example, when JOHANSSON took control of National, he listed his 
former prison mate, W.S., as the President, Secretary, 
Treasurer, and Director of National on many corporate filings.  
JOHANSSON even created a fictional persona, “Keith Golatta,” to 
use as an alias on corporate filings.  On telephone 
conversations with National’s customers and in other instances, 
JOHANSSON sometimes said that he was “Keith Golatta,” even 
though no such person existed. 
27. 
After JOHANSSON failed to satisfy the tax judgment, in 
2012 the IRS filed a tax lien against CBSA, a family partnership 
controlled by JOHANSSON’s wife, which owned the industrial 
property in Corona where National was based.  The IRS alleged 
that CBSA was JOHANSSON’s nominee. 
28. 
On or about September 25, 2012, D.L.V., one of 
JOHANSSON’s welders at National, was almost killed in an 
explosion during a welding repair on one of National’s tankers.  
29. 
On or about May 6, 2014, S.E., JOHANSSON’s other 
welder at National, was killed by an explosion when his welding 
torch ignited fumes inside one of National’s tankers.  As with 
the fatal 1993 explosion at Atlas and the 2012 explosion at 
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National, the welding was taking place at JOHANSSON’s company 
even though the company lacked the federally required “R” Stamp 
to conduct such welding.  D.L.V., the same welder who narrowly 
survived the 2012 explosion, was seriously injured during the 
explosion on or about May 6, 2014.   
30. 
An investigation into the deadly explosion on May 6, 
2014 ensued.  During the investigation, JOHANSSON continued to 
conceal his ownership and control of National.  For example, on 
or about May 6, 2014, JOHANSSON told investigators that he was a 
customer service representative at National.  JOHANSSON also 
claimed that he was merely a “temp” and “paper pusher” at 
National.  To cover his tracks, in the weeks after the explosion 
in May 2014, JOHANSSON arranged for National to hire a staffing 
company to hire JOHANSSON as a temp at National, even though 
JOHANSSON owned and controlled National. 
2. 
Wholesale Distribution, Inc.  
31. 
As a result of the deadly explosion in May 2014, 
federal regulators imposed strict restrictions on the operations 
at National.  To evade those restrictions, JOHANSSON shut down 
National and started a nearly identical company, Wholesale 
Distribution Services, Inc. dba Quality Services (“Wholesale”), 
in late 2014 and early 2015.  Wholesale operated out of the same 
warehouse as National, operated the same trucks, and had most of 
the same drivers and office staff as National.  As he had done 
at National, JOHANSSON listed a “straw man” -- J.C., who sold 
tires to JOHANSSON -- as Wholesale’s President and Owner on 
corporate records, even though J.C. had almost no involvement in 
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Wholesale.  J.C. has confirmed that he was unaware that 
JOHANSSON used his name and signature on Wholesale’s corporate 
filings for years.  
32. 
Bank records and employee interviews confirm that, 
from 2015 to the present, JOHANSSON has controlled every aspect 
of Wholesale, from operations to finances to criminal defense 
issues.  Every employee of Wholesale ultimately answers to 
JOHANSSON.  It was not until JOHANSSON and Wholesale were 
indicted in the Pending Criminal Case in 2018 that JOHANSSON 
finally began publicly admitting the scope of his involvement in 
Wholesale.  In the Pending Criminal Case, JOHANSSON repeatedly 
has described himself as the corporate representative of 
Wholesale.   
3. 
“Company A” 
33. 
As noted above, Company A is a trucking company based 
in Gustine, California that hauls agricultural products.  During 
the investigation into, and civil litigation regarding, the 
death of JOHANSSON’s welder on or about May 6, 2014, JOHANSSON 
consistently downplayed his role at Company A.  For example, 
JOHANSSON acknowledged that he had been a member of Company A’s 
Board of Directors, but claimed that he was only a consultant 
and that he had no knowledge as to who owned Company A.  Based 
on my training and experience and my knowledge of the facts of 
this case, I believe that JOHANSSON was deliberately minimizing 
his role at, and command of, Company A.  For example, as a 
result of my investigation, I am aware of the following 
information: 
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a. 
Even though JOHANSSON has claimed, under oath, 
that he does not know who owns Company A, JOHANSSON’s own 
company, Systems Logistics, Inc. dba Tech Logistics (“Tech 
Logistics”), bought Company A in around 2003.  While JOHANSSON 
also has tried to distance himself from Tech Logistics, he 
himself signed the Stock Purchase Agreement in which Tech 
Logistics bought Company A in 2003, in his capacity as Tech 
Logistics’ Managing Director.  (JOHANSSON’s wife signed the same 
agreement as the buyer’s President.)  Likewise, a document 
obtained from the California Secretary of State, entitled 
“Statement of Information” and dated October 14, 2003, shows 
that JOHANSSON signed the document and described himself as the 
Managing Director of Tech Logistics.  JOHANSSON’s personal 
attorney in Newport Beach was listed on the same document as 
Tech Logistics’ registered agent for service of process.  
b. 
Even though JOHANSSON has claimed, under oath, 
that he had a very limited role at Company A, documents obtained 
from the California Secretary of State show that:  (1) on or 
about July 19, 2015, JOHANSSON -- using the alias “Brad Johnson” 
-- filed an Amended Articles of Incorporation for Company A, in 
which he stated under oath that he was the President and 
Secretary of Company A and in which he slightly modified the 
company’s name; and (2) on or about September 21, 2015, 
JOHANSSON, again using the alias “Brad Johnson,” filed an 
Amended Articles of Incorporation, in which he stated that he 
was the President and Secretary of the newly named company and 
in which he changed the name of the company back to Company A’s 
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14 
original name. 
c. 
A similar document, dated on or about October 27, 
2010, lists “Keith Golwick” as Tech Logistics’ Director.  Based 
on my investigation in this case, I believe that “Keith Golwick” 
may be another of JOHANSSON’s aliases.  As set forth above, it 
is well established that JOHANSSON frequently used the alias 
“Keith Golatta” to conceal his involvement in National.  (I have 
checked law enforcement databases for individuals named “Keith 
Golatta” and “Keith Golwick” and found no individuals with those 
names during the relevant time periods.) 
d. 
Documents obtained from another bank (“Bank B”) 
confirm JOHANSSON’s longstanding financial control of Company A.  
For example, a document entitled “Accounts Receivable Financing 
and Security Agreement,” between Bank B and Company A and dated 
or about July 5, 2006, listed JOHANSSON as the CEO of Company A 
and JOHANSSON’s wife as the Director of Company A.  A related 
document from Bank B, entitled “Lockbox Service” and dated on or 
about March 4, 2015, was signed by JOHANSSON, who described 
himself as Company A’s Director.  According to “Company A’s 
Manager” (who has been the onsite manager for Company A’s truck 
yards in Turlock and Gustine for the last two decades), the 
financing of Company A’s receivables allowed for money to be 
borrowed by Company A against future payments from customers.  
In an interview, Company A’s Manager said that the first draw of 
the loan -- which amounted to several hundred thousand dollars  
-- was transferred to JOHANSSON and not used by Company A.   
e. 
Company A’s Manager said in prior sworn testimony 
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15 
that, ever since Tech Logistics acquired Company A in 2003, 
JOHANSSON has controlled Company A’s Manager’s employment at 
Company A, acquired trucks for Company A, and handled all of 
Company A’s insurance policies for its trucks.  Company A’s 
Manager repeated these statements in an interview in June 2021, 
adding that JOHANSSON’s wife assisted on insurance issues.  
f. 
JOHANSSON commonly obtained insurance policies 
that covered National’s (and Wholesale’s) trucks as well as 
Company A’s trucks.  Several such documents listed, for example, 
the insured as “National Distribution Services, Inc. DBA 
[Company A].”  
B. 
JOHANSSON’s Formation of Western Distribution, LLC in 
Early 2019 
34. 
According to documents filed with the Wyoming 
Secretary of State and emails between JOHANSSON and Wyoming 
Corporate Services, Inc. (which appears to be a dba of Capital 
Administrations, LLC, the “Registered Agent” for Western 
Distribution, LLC in Wyoming), JOHANSSON caused Western 
Distribution, LLC to be registered as an LLC in Wyoming on or 
about March 6, 2019.  To my knowledge, this marked the formation 
of Western Distribution, LLC as a legal entity.1  JOHANSSON was 
billed approximately $1,120 by the Registered Agent to set up 
the LLC.   
 
1 A document entitled “Operating Agreement Member Managed,” 
allegedly dated February 25, 2019, purports to show the 
formation date of Western Distribution, LLC as on or about 
February 25, 2019.  The date on that document does not appear to 
be credible given that the same document states that the 
company’s Articles of Organization were filed with the Wyoming 
Secretary of State on or about March 6, 2019.   
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16 
35. 
Emails between JOHANSSON and the Registered Agent 
confirm JOHANSSON’s role in the creation of Western 
Distribution, LLC.  For example, JOHANSSON used his own name, 
email address, and phone number when communicating with the 
Registered Agent.  
36. 
An IRS Form SS-4, dated on or about March 14, 2019, 
establishing the Employer Identification Number for Western 
Distribution, LLC, was sent to JOHANSSON as a member of the LLC. 
37. 
According to a document entitled “Application to 
Register a Foreign Limited Liability Company LLC” from the 
California Secretary of State’s website, Western Distribution, 
LLC was registered as a Wyoming LLC in the State of California 
on or about April 22, 2019.  
38. 
On or about April 25, 2019, JOHANSSON submitted a Form 
MCSA-1 to register Western Distribution, LLC with the Federal 
Motor Carrier Safety Administration (“FMCSA”).  The Form MCSA-1 
is an application that businesses use in order to register with 
FMCSA.  In response to a question asking the applicant to list 
the names of its officers, JOHANSSON listed himself. 
39. 
The MCSA-1 Form asked, “Do you currently have, or have 
you had within the last 3 years of the date of filing this 
application, relationships involving common stock, common 
ownership, common management, common control or familial 
relationships with any FMCSA-regulated entities?”  Even though 
JOHANSSON was the sole officer of Wholesale and Wholesale was a 
FMCSA-regulated entity (because, for example, it transported jet 
fuel in interstate commerce), JOHANNSON checked “No.”  In the 
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17 
“APPLICANT’S OATH” field, JOHANSSON’s name was printed and 
digitally signed.  JOHANSSON expressly verified that “all 
information supplied on this form or relating to this 
application is true and correct.”2   
C. 
JOHANSSON’s Fraudulent Use of Advanced Fuel Delivery’s 
Name and DOT Registration Number 
40. 
Advanced Fuel Delivery, LLC (“Advanced”) was a 
trucking company based in Riverside.  According to an interview 
of “Advanced’s Managing Partner” in June 2021, Advanced was 
planning to shut down its operations in 2019.  In 2019, 
JOHANSSON offered the owners of Advanced approximately $25,000 
to purchase the company’s name and licenses.  The owners 
rejected JOHANSSON’s offer for being too low.  
41. 
Thereafter, JOHANSSON appears to have started using 
Advanced’s name and DOT registration number (3049566) as his 
own.  In interviews in June 2021, Advanced’s Managing Partner 
said that (1) he had no knowledge that JOHANSSON was using 
Advanced’s name and DOT registration number, and (2) there was 
no reason for Advanced to apply for insurance policies in 2019 
because the company was winding down.  Even though JOHANSSON had 
no ownership rights in Advanced, he applied for and obtained 
insurance for his companies using Advanced’s name and DOT 
registration number in 2019 and 2020.  Documents obtained from 
the insurer show, for example: 
a. 
A Commercial Insurance Application, dated on or 
 
2 On or about December 9, 2020, shortly after JOHANSSON 
learned of this investigation, Western Distribution, LLC 
submitted another Form MCSA-1 in which it admitted that it did 
share common management with Wholesale.  
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18 
about June 18, 2019, listed Advanced as the applicant and 
included a “dba Advanced Distribution” as well as “Western 
Distribution” as another “Named Insured.”  The contact name for 
the applicant is “Jay Johnson,” who listed his email address as 
JOHANSSON’s email address at Western Distribution, LLC and his 
phone number as the phone number that JOHANSSON commonly listed 
for Western Distribution, LLC (XXX-XXX-6840).3  In response to 
the question of whether the applicant has been indicted for any 
crime of fraud, “Jay Johnson” responded, “N.”   
b. 
An insurance document entitled “Risk Engineering 
Field Evaluation,” dated on or about August 24, 2020, also 
listed the contact for Advanced as a “Jay Johnson,” who again 
used JOHANSSON’s email account at Western Distribution, LLC as 
well as the same phone number associated with JOHANSSON.  The 
Evaluation reports listed Advanced’s DOT number (3049566) and 
observed that “Jay runs the business day to day” and has “[b]een 
in the petroleum distribution business for 25 years.”   
c. 
A follow-up insurance policy, dated on or about 
November 19, 2020, listed the insured as “Advanced Distribution, 
Inc. dba Western Distribution.”  
d. 
“Jay Johnson,” again using JOHANSSON’s email 
 
3 This phone number appears to have been used previously by 
J.S., one of JOHANSSON’s shop employees at Wholesale 
Distribution, Inc.  When J.S. left Wholesale, JOHANSSON appears 
to have begun using the number himself.  For example, phone 
records for the same number (XXX-XXX-6840) show that between 
approximately February 2019 and August 2020, the user of this 
phone number called a phone number associated with JOHANSSON’s 
wife approximately 3,590 times.  Likewise, in an email dated on 
or about May 13, 2021, Western Distribution, LLC’s dispatcher 
wrote to a client that the company’s “Admin Manager” was “Brad” 
and listed the same -6840 number as “Brad’s” number.   
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19 
address at Western Distribution, LLC and listing the -6840 phone 
number as his cell phone, emailed the insurer repeatedly about 
the policy, purportedly on behalf of Advanced.  In one such 
email, dated on or about September 24, 2020, “Jay Johnson” asked 
the insurer for a discounted premium based on Advanced’s “almost 
3 years claims free,” apparently alluding to the safety record 
of a company unrelated to the trucking companies that JOHANSSON 
actually owned.4     
42. 
Based on my training and experience, my knowledge of 
this investigation, and my discussions with colleagues at the 
DOT, I believe that “Jay Johnson” is yet another of JOHANSSON’s 
aliases and that JOHANSSON was applying for insurance -- using 
an alias and a different trucking company’s name and DOT number 
-- to “piggy back” off of Advanced’s prior safety ratings while 
concealing his own involvement in the scheme, which very likely 
amounts to insurance fraud.   
D. 
JOHANSSON’s Decision to Make Western Distribution, LLC 
a Defunct Entity as of September 2019  
43. 
On or about July 23, 2019, JOHANSSON sent an email 
entitled “Western Distribution LLC” to the Registered Agent in 
Wyoming.  In the email, JOHANSSON asked, “1.  Can Western 
Distribution LLC be changed to a Corporation?  2.  Is the name: 
Advanced Distribution, Inc. available?”  (Emphases in original.)  
The Registered Agent replied to JOHANSSON in the affirmative. 
 
4 The “Risk Engineering Field Evaluation” discussed above 
states that “Jay Johnson” told the insurer that the company 
hauled “no aviation fuels,” even though, according to Co-
conspirator #2, Western Distribution, LLC’s primary business was 
hauling jet fuel.  
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20 
44. 
According to a corporate resolution for Advanced 
Distribution, Inc. dated or about September 10, 2019 and filed 
with the Wyoming Secretary of State, “the Director, Carl 
Johansson, shall have full power and authority to act on behalf 
of Advanced Distribution, Inc.”   
45. 
According to documents filed with the Wyoming 
Secretary of State and emails between JOHANSSON and the 
Registered Agent, on or about September 12, 2019, JOHANSSON 
caused Western Distribution, LLC to be converted into Advanced 
Distribution, Inc., a Wyoming corporation.   
46. 
According to documents obtained from the Registered 
Agent, JOHANSSON requested, and was billed approximately $495, 
for the conversion from the LLC to the corporation and the name 
change from Western Distribution to Advanced Distribution.  
47. 
According to a document entitled “Certificate of 
Conversion” from the Wyoming Secretary of State, “Western 
Distribution LLC, a Wyoming Limited Liability Company[,] 
Converted to Western Distribution, Inc., a Wyoming For Profit 
Corporation, On September 12, 2019.”   
48. 
According to documents filed with the Wyoming 
Secretary of State and emails between JOHANSSON and the 
Registered Agent, on or about September 16, 2019, JOHANSSON 
caused Advanced Distribution, Inc. to change its name to Western 
Distribution, Inc.   
49. 
On or about September 17, 2019, the Registered Agent 
emailed confirmation of the name change to JOHANSSON, and wrote, 
in an email entitled “Western Distribution, Inc.,” “Hello Brad, 
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21 
Please see attached Name Change for your company Western 
Distribution, Inc.”  Attached to the email was a “Certificate of 
Name Change” from the Wyoming Secretary of State, dated on or 
about September 16, 2019, that stated, in relevant part: 
“Current Name: Western Distribution, Inc.  Old Name: Advanced 
Distribution, Inc.”   
50. 
Based on the foregoing documents, to my knowledge, 
after on or about September 12, 2019, Western Distribution, LLC 
no longer existed as a legal entity.  Instead, that entity had 
been converted, first, to Advanced Distribution, Inc., and then, 
a few days later, to Western Distribution, Inc., all at the 
direction of JOHANSSON.5 
51. 
Based on my training and experience, and my knowledge 
of this investigation, it is highly unusual for someone to 
convert their LLC into a corporation and change its name twice 
in one week.  It is even more unusual for someone to then 
disregard the newly formed corporation and continue operating 
the business as a defunct LLC.  I am not aware of any legitimate 
purpose for such a scheme; to the contrary, while this 
investigation is ongoing, I believe that JOHANSSON’s changes to 
the names and legal formulations of Advanced and Western 
Distribution were likely motivated by the insurance fraud scheme 
 
5 On or about June 10, 2021, Western Distribution, LLC filed 
its biennial update with the California Secretary of State, in 
which the company claimed that it remained an active LLC in 
Wyoming.  That was false, as the only active entity in Wyoming 
is the corporation that JOHANSSON caused to be established in 
September 2019.  Nothing in the LLC’s filings in Wyoming or 
California suggests that the LLC has been reconstituted 
elsewhere.  
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22 
described above.  I also am not aware of any legitimate reason 
why (as detailed below) JOHANSSON would apply for the PPP loan 
in the name of the defunct LLC rather than in the name of the 
new corporation.  JOHANSSON’s personal involvement in the highly 
unusual conversion of the LLC to a corporation in September 
2019, as well as the PPP application in April 2020, causes me to 
conclude that it is extremely unlikely that he continued 
operating the defunct LLC by accident.   
E. 
JOHANSSON’s Control of Western Distribution, LLC 
52. 
Based on an interview of Co-conspirator #2 in April 
2021 as well as previous interviews of Co-conspirator #2, I 
learned the following:  
a. 
Co-conspirator #2 has worked for JOHANSSON for 
nearly three decades, including at National, Wholesale, and 
Western Distribution, LLC.  At each company, her main 
responsibility has been handling the administrative side of 
JOHANSSON’s business.   
b. 
JOHANSSON was (and is) the Managing Director of 
Western Distribution, LLC.  Western Distribution, LLC had many 
of the same management and employees as did Wholesale, which 
JOHANSSON also controlled and managed.  JOHANSSON set up Western 
Distribution, LLC because he anticipated being sent to prison in 
the Pending Criminal Case, and he envisioned his son, Co-
conspirator #1, running the new company while he was in prison.   
c. 
JOHANSSON had the power to, and did, write checks 
for Western Distribution, LLC.  He determined his own pay and 
determined the amount of Co-conspirator #1’s pay.   
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23 
d. 
Although JOHANSSON often listed his son, Co-
conspirator #1, as the owner of Western Distribution, LLC, Co-
conspirator #1 had almost no management role at the company.   
53. 
Based on my review of bank records relating to Western 
Distribution, LLC, I learned that JOHANSSON was the sole 
signatory on each of the company’s bank accounts.  
54. 
Based on credit reports, academic records, and my own 
research, I know that for most of the time that Co-conspirator 
#1 has been the alleged owner of Western Distribution, LLC, he 
has held a day job as an entry-level financial analyst at an 
investment firm in Long Beach.  Co-conspirator #1 graduated from 
college in around 2019, lives with his parents, and, aside from 
his alleged ownership of Western Distribution, LLC, has no known 
experience in the trucking industry.  I am aware of no evidence 
that Co-conspirator #1 had any role in Western Distribution, 
LLC’s PPP loan application in April 2020 (detailed below), other 
than purportedly reviewing and signing certain documents.6  
F. 
Western Distribution, LLC’s First PPP Loan Application 
in April 2020 
55. 
In order to apply for the PPP loan, JOHANSSON opened a 
new bank account at a federally insured bank (the “Bank”) in 
Modesto, California.  To do so, JOHANSSON caused Western 
Distribution, LLC to submit a number of documents to the Bank in 
around April 2020, including a Beneficial Ownership 
Certification Form, dated on or about April 22, 2020, the 
 
6 As discussed below, Co-conspirator #1 played a larger role 
in Western Distribution, LLC’s loan forgiveness application and 
second PPP loan application in 2021.  
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24 
express purpose of which was “[t]o help the government fight 
financial crime” because “Legal Entities can be abused to 
disguise involvement in . . . tax evasion, corruption, fraud, 
and other financial crimes.”  The form asked for the name “of 
one individual with significant responsibility for managing the 
Legal Entity,” i.e., Western Distribution, LLC.  The response 
listed Co-conspirator #1 and claimed that he was the CEO of 
Western Distribution, LLC.  
56. 
According to Co-conspirator #2 (JOHANSSON’s office 
administrator), JOHANSSON instructed her to fill out the PPP 
loan application, and she emailed it to JOHANSSON for his 
approval.   
57. 
Western Distribution, LLC’s PPP loan application, 
dated on or about April 24, 2020 and submitted to the Bank, 
included the following: 
a. 
Western Distribution, LLC checked the box for 
being an LLC, not one of the boxes for corporations.  
b. 
Western Distribution, LLC listed its average 
monthly payroll as $174,556, for 31 employees.  
c. 
Western Distribution, LLC requested a PPP loan in 
the amount of $436,390 (i.e., approximately 2.5 times its 
average monthly payroll).  
d. 
Co-conspirator #1 was listed as the owner of 100% 
of Western Distribution, LLC.  The social security number listed 
was the one associated with Co-conspirator #1. 
e. 
Question #3 of the loan application stated: “Is 
the Applicant or any owner of the Applicant an owner of any 
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25 
other business, or have common management with, any other 
business?  If yes, list all such businesses and describe the 
relationship on a separate sheet identified as addendum A.”  The 
response was marked as “No,” and no addendum A was included.  
f. 
Question #5 of the loan application stated: “Is 
the applicant or any individual owning 20% or more of the equity 
of the Applicant subject to an indictment, criminal information, 
arraignment, or other means by which formal criminal charges are 
brought in any jurisdiction ...?”  The response was marked as 
“No” and the initials “CJ” were handwritten next to the 
response.7 
g. 
The loan application contained a number of 
certifications regarding the applicant’s compliance with PPP 
regulations, including, for example, “The funds will be used to 
retain workers and maintain payroll or make mortgage interest 
payments, lease payments, and utility payments, as specified 
under the Paycheck Protection Rule; I understand that if the 
funds are knowingly used for unauthorized purposes, the federal 
government may hold me legally liable, such as for charges for 
fraud.”  The initials “CJ” were handwritten next to this 
statement.   
h. 
Under all of the certifications, the form was 
signed in Co-conspirator #1’s name as the “Member (owner)” and 
dated on or about April 24, 2020.   
58. 
In order to support the value of payroll expenses 
 
7 JOHANSSON and Co-conspirator #1 both have the initials 
“C.J.” 
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26 
associated with the PPP loan, Western Distribution, LLC provided 
the Bank with two documents from Paychex (a payroll services 
company), both entitled “Payroll Report” and covering the first 
quarter of 2020, showing the payroll expenses of Western 
Distribution, LLC.  The Quarterly Reports showed the following:  
a. 
Western Distribution, LLC had two accounts at 
Paychex:  (1) an account ending in -6410, covering approximately 
24 employees (who appear to be Western Distribution, LLC’s truck 
drivers); and (2) an account ending in -6403, covering 
approximately 16 employees (who appear to be Western 
Distribution, LLC’s administrative staff and shop employees). 
b. 
JOHANSSON was an employee who was being paid 
wages. 
c. 
Co-conspirator #1 was not listed anywhere. 
59. 
A Paychex document entitled “Paycheck Protection 
Program Data,” dated on or about April 5, 2020 and also 
submitted to the Bank, combined the data from the Payroll 
Reports and showed Western Distribution, LLC’s total payroll 
costs for the first quarter of 2020 as $187,256.97.  
G. 
Company A’s PPP Loan Application in April 2020 
60. 
As set forth above, JOHANSSON has controlled Company A 
since approximately 2003.  Company A’s Manager (the long-time 
onsite manager for Company A and the company’s former owner), 
confirmed in an interview in June 2021 that JOHANSSON and 
JOHANSSON’s wife remain in control of Company A.   
61. 
Company A’s Manager also confirmed that JOHANSSON and 
JOHANSSON’s wife directed him to apply for a PPP loan in around 
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27 
April 2020.  Company A’s Manager said that JOHANSSON instructed 
him on how to answer almost every question on Company A’s PPP 
loan application. 
62. 
Company A applied for a PPP loan, through its 
federally insured bank, on or about April 15, 2020.  Its 
application included the following: 
a. 
The average monthly payroll was listed as 
$114,602, for 25 employees.  The amount requested was $286,505 
(i.e., approximately 2.5 times the average monthly payroll).   
b. 
The owner of Company A was listed as JOHANSSON’s 
85-year-old mother, who was described as owning 100% of the 
company.  The address listed for JOHANSSON’s mother corresponded 
to an actual address of JOHANSSON’s mother, and the Social 
Security Number listed corresponded to JOHANSSON’s mother as 
well.  
c. 
Question #3 of the loan application stated: “Is 
the Applicant or any owner of the Applicant an owner of any 
other business, or have common management with, any other 
business?  If yes, list all such businesses and describe the 
relationship on a separate sheet identified as addendum A.”  The 
response was marked as “No,” and no addendum A was included.  
d. 
Question #5 of the loan application form stated: 
“Is the applicant or any individual owning 20% or more of the 
equity of the Applicant subject to an indictment, criminal 
information, arraignment, or other means by which formal 
criminal charges are brought in any jurisdiction…?”  The 
response was marked as “No” and the initials of Company A’s 
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28 
Manager were digitally signed next to the response.  
e. 
Under all of the certifications, the form was 
digitally signed by Company A’s Manager and dated on or about 
April 24, 2020. 
63. 
Company A’s Manager told me in June 2021 that he had 
no idea who owned Company A, but that he listed Johansson’s 
mother because JOHANSSON instructed him to do so.  Likewise, 
Company A’s Manager said that JOHANSSON instructed him regarding 
how to answer the questions about whether any of the company’s 
owners had been indicted, and whether Company A had any common 
management with other entities.   
64. 
When law enforcement attempted to interview 
JOHANSSON’s mother in June 2021, she said that she did not 
remember if she owned a company called Company A because her 
late husband owned several companies.  (Her husband died in 
2004.)  She had no recollection of applying for a government 
loan in Company A’s name, and she said that she was not familiar 
with the name of Company A’s Manager (despite the fact that 
Company A’s Manager has been Company A’s most senior employee 
for decades).  Similarly, when Company A’s Manager was 
interviewed in June 2021, he said that he had never heard of 
JOHANSSON’s mother until JOHANSSON directed him to list her as 
the owner on the PPP application.   
65. 
Based on Company A’s representations, Company A’s bank 
issued a PPP loan to Company A in the amount of $286,500 on or 
about May 6, 2020.  
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29 
H. 
Western Distribution, LLC’s Expenditure of Its First 
PPP Loan  
66. 
During an interview in around April 2021, Co-
conspirator #2 (JOHANSSON’s office administrator) told me the 
following: 
a. 
Once the COVID pandemic hit in March 2020, almost 
all of Western Distribution, LLC’s business stopped and most of 
the company’s employees were put on unemployment for 
approximately five months.   
b. 
The company did not rehire most of those 
employees until approximately August or September 2020.  Nor did 
the company pay most of the employees it had laid off during 
that period.  An exception to this was that JOHANSSON put his 
two sons on payroll after receiving the PPP loan; these were the 
only “employees” on Western Distribution, LLC’s Paychex payroll 
from approximately April to August 2020.  
67. 
As part of this investigation, I obtained and analyzed 
bank records from Bank of America for Western Distribution, LLC.  
The analysis of the Bank of America account ending in -6403 
showed that approximately $435,000 of PPP loan funds were 
received between on or about May 7, 2020 and June 11, 2020.  The 
analysis further showed that by on or about June 15, 2020, all 
proceeds from the PPP funding had been spent.  Specifically: 
a. 
On or about May 6, 2020 (i.e., just before the 
PPP funds were disbursed), Account -6403 had an ending balance 
of $614.08.  On or about May 7, 2020, this account received the 
initial PPP deposit of $85,000.  On or about May 12, 2020, the 
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30 
account had an ending balance of $284.66.  During this period, 
the entire $85,000 was either paid directly towards business 
expenses or payroll, or transferred to other accounts where it 
was subsequently spent.   
b.
On or about May 13, 2020, Account -6403 had an
ending balance of $65.49.  On or about May 14, 2020, this 
account received a PPP deposit of $75,000.  On or about May 15, 
2020, the account had an ending balance of $14,344.65.  On or 
about May 15, 2020, $38,909.58 was either paid directly towards 
business expenses or payroll, or transferred to other accounts 
where it was subsequently spent. 
c.
Similarly, Account -6403 received the following
PPP payments:   
i. $50,000 on or about May 19, 2020;
ii. $25,000 on or about May 22, 2020;
iii. $20,000 on or about May 26, 2020;
iv. $22,000 on or about May 28, 2020;
v. $25,000 on or about May 29, 2020;
vi. $39,000 on or about June 3, 2020;
vii. $25,000 on or about June 4, 2020;
viii. $40,000 on or about June 5, 2020; and
ix. $29,000 on or about June 11, 2020.
d.
The PPP payments that Western Distribution, LLC
received between on or about May 7, 2020 and June 11, 2020 
totaled approximately $435,000.  As of on or about June 15, 
2020, the ending balance in Account -6403 was $2,422.13.  All 
$435,000 was either paid directly towards business expenses or 
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31 
payroll, or transferred to other accounts where it was 
subsequently spent.   
e.
In terms of how much of the PPP funds Western
Distribution, LLC actually spent on payroll, according to 
Paychex and tax documents, the only two employees that WESTERN 
paid in the second quarter of 2020 (i.e., April through June 
2020, when the company spent the PPP funds) were JOHANSSON’s two 
sons: Co-conspirator #1 (the purported owner of Western 
Distribution, LLC) and his brother.  For example, a document 
entitled, “Quarterly Contribution Return and Report of Wages,” 
covering Western Distribution, LLC’s second quarter of 2020, 
lists JOHANSSON’s two sons as the company’s only paid employees 
for that quarter.   
f.
Although the remainder of Western Distribution,
LLC’s employees were no longer paid via Paychex in the second 
quarter of 2020, an analysis of the company’s bank records shows 
that the company did continue paying a handful of employees via 
company checks (i.e., off of Paychex’s books).  For the period 
from on or about May 7, 2020 to June 11, 2020 (i.e., when 
Western Distribution, LLC spent its PPP loan proceeds), these 
company checks to employees totaled approximately $91,731.   
68.
An Employee Earnings Record for Western Distribution,
LLC, dated on or about September 18, 2020, shows Co-conspirator 
#1 as having a hire date of on or about May 16, 2020, i.e., 
approximately eight days after the PPP loan was funded.  As 
stated above, none of the documentation submitted by Western 
Distribution, LLC to the Bank as part of the PPP loan 
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32 
application showed any payroll expenses for Co-conspirator #1.  
It was only after the loan was processed in his name that Co-
conspirator #1 was added to the payroll for Western 
Distribution, LLC.  Based on my training and experience, and my 
knowledge of this investigation, this indicates that JOHANSSON 
was trying to create the appearance that his son was working at 
the business in conjunction with the funding of the loan which 
was dependent on his son’s alleged representations as the 
purported owner.   
I. 
The Transfer of Company A’s Employees to Western 
Distribution, LLC’s Payroll Account 
69. 
To be eligible for forgiveness of a PPP loan, a 
borrower was required to spend at least sixty percent of its PPP 
loan on payroll expenses within 24 weeks after the PPP loan was 
issued.  Western Distribution, LLC’s 24-week deadline was on or 
about October 19, 2020.  In September 2020, having laid off many 
of its employees from approximately April 2020 to August 2020, 
Western Distribution, LLC would have been unable to meet the 
sixty-percent threshold, and thus would have been ineligible for 
forgiveness of the entire loan, meaning the company, i.e., 
JOHANSSON, would have had to pay back a portion of the PPP funds 
to the Bank.  Accordingly, in or about September 2020, JOHANSSON 
began implementing a scheme to transfer many of the employees of 
Company A onto the payroll of Western Distribution, LLC, so that 
Company A’s payroll expenses for those employees could be 
counted as Western Distribution, LLC’s payroll expenses, so that 
Western Distribution, LLC could deceive the Bank into believing 
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33 
that Western Distribution, LLC had met the sixty-percent 
threshold.  My bases for the foregoing conclusions include the 
following:  
a. 
On or about September 22, 2020, Western 
Distribution, LLC directed that 21 of Company A’s employees (the 
“21 Company A Employees”) in Company A’s Paychex account be 
added to Western Distribution, LLC’s Paychex account (effective 
on or about September 16, 2020).8  From that date until at least 
December 2020, the 21 Company A Employees were issued paychecks 
by Western Distribution, LLC. 
b. 
In an interview in June 2021, Company A’s Manager 
said the following: 
i. 
At no point from September 2020 through 
December 2020 did any of the 21 Company A Employees work for 
Western Distribution, LLC.  
ii. 
JOHANSSON devised the scheme to put the 21 
Company A Employees on the payroll of Western Distribution, LLC 
by means of transferring them to Western Distribution, LLC’s 
account at Paychex.   
c. 
Email records corroborate the statement of 
Company A’s Manager that JOHANNSON directed Company A to 
transfer its employees to Western Distribution, LLC’s Paychex 
account.  For example, on or about September 10, 2020, JOHANSSON 
emailed the wife of Company A’s Manager (who was Company A’s 
office manager), asking to discuss the requirements of the loan 
 
8 The 21 Company A Employees were D.A., D.A., G.B., J.C.B., 
J.C., M.C., N.E., J.F., R.G., G.H., T.H., J.H., D.M., J.M., 
R.M., C.M., E.M., D.O., E.P., B.P., and J.W.  
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34 
forgiveness application.  Beginning on or about September 21, 
2021, JOHANSSON and the wife of Company A’s Manager exchanged 
emails regarding JOHANSSON’s proposal to create a “sub-account” 
within Western Distribution, LLC’s Paychex account for Company 
A’s employees.  JOHANSSON sent to the wife of Company A’s 
Manager the contact information for the Paychex representative 
with whom JOHANSSON had spoken about setting up Company A’s 
“sub-account.”  And when there were delays regarding the 
paystubs for the 21 Company A Employees, the wife of Company A’s 
Manager emailed JOHANSSON to complain on or about October 6, 
2020, and JOHANSSON responded a few minutes later saying that he 
had just mailed them to her.  On some of these emails, JOHANSSON 
used his personal email account rather than his account at 
Western Distribution, LLC.   
d.
In an interview, Company A’s Manager also said
that JOHANSSON forced Company A to cover the payroll expenses 
for the 21 Company A Employees during the duration of the 
scheme.  Company A’s Manager said that Company A had to wire the 
payroll expenses for the 21 Company A Employees to Western 
Distribution, LLC even after those employees were shifted to 
Western Distribution, LLC’s Paychex account.  In other words, 
even though JOHANSSON would later represent to the Bank that the 
PPP funds that Western Distribution, LLC had received had been 
spent (in part) on the 21 Company A Employees, that was false:  
Company A was having to pay the payroll expenses of those 
employees out of Company A’s own accounts.  According to Company 
A’s Manager, JOHANSSON did not use Western Distribution, LLC’s 
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35 
own funds to pay the 21 Company A Employees.     
e.
Bank records corroborate the statement of Company
A’s Manager that JOHANSSON made Company A reimburse Western 
Distribution, LLC for the payroll expenses of the 21 Company A 
Employees.  Wire transfer records show that beginning in late 
September 2020 and continuing through December 2020, Company A 
sent approximately 26 wire transfers to Western Distribution, 
LLC totaling approximately $339,900, in amounts tied to the 
payroll expenses for the 21 Company A Employees who had been 
moved to Western Distribution, LLC’s payroll.  
f.
Email records also show that JOHANSSON apparently
did not see any need for the scheme to continue into 2021.  For 
example, on or about December 28, 2020, JOHANSSON wrote to the 
wife of Company A’s Manager, “[M]ake this the last week ... go 
back to your own next week.”  (Ellipsis in original.)  The next 
day, the wife of Company A’s Manager wrote to Paychex, “We will 
go ahead and run the weekly payroll information we have you 
yesterday under the Western trucker account.... We will go back 
to everyone under the [Company A] account next week.”  
J.
Western Distribution, LLC’s Fraudulent PPP Loan
Forgiveness Application
70.
Western Distribution, LLC submitted a PPP loan
forgiveness application to the Bank on or about January 19, 
2021.  To be eligible for forgiveness of the PPP loan, Western 
Distribution, LLC was required to submit documentation of how it 
spent the PPP loan proceeds, including documents regarding 
payroll, rent, etc.   
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36 
71. 
According to Co-conspirator #2, she filled out the PPP 
loan forgiveness application at JOHANSSON’s direction.  
72. 
The PPP loan forgiveness application form contained a 
number of certifications regarding the borrower’s compliance 
with PPP regulations.  For example: 
a. 
“The dollar amount for which forgiveness is 
requested was used to pay costs that are eligible for 
forgiveness”; 
b. 
“I understand that if the funds were knowingly 
used for unauthorized purposes, the federal government may 
pursue recovery of loan amounts and/or civil or criminal fraud 
charges”; and 
c. 
“The information provided in this application and 
the information provided in all supporting documents and forms 
is true and correct in all material respects.” 
73. 
Next to each of these certifications, the initials 
“CJ” were handwritten.  The certification was signed in the name 
of Co-conspirator #1, who described himself as the LLC Member 
and dated the form “1/19/21.”  The handwriting of the signature, 
as well as the handwritten initials “CJ” on the same page next 
to the certifications, look nothing like the signature and 
handwritten initials on Western Distribution, LLC’s PPP loan 
application.  While I am by no means a handwriting expert, based 
on my training and experience, and my knowledge of this 
investigation (including the fact that JOHANSSON learned of the 
investigation in late 2020), I believe that JOHANSSON had Co-
conspirator #1 sign the loan forgiveness application, whereas I 
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37 
believe that in April 2020 JOHANSSON likely signed the PPP loan 
application forms using Co-conspirator #1’s name.9  
74.
The payroll records from Paychex that Western
Distribution, LLC submitted to the Bank as part of the loan 
forgiveness application listed the employees not only from 
Western’s own Paychex accounts (-6403 and -6410), but also a 
separate account (-0968) including the 21 Company A Employees as 
well as eight employees of a Texas company associated with 
JOHANSSON.  Specifically, Western Distribution, LLC provided the 
Bank a spreadsheet entitled “PPP Forgiveness Data,” dated on or 
about December 11, 2020, purporting to show Western 
Distribution, LLC’s payroll expenses from on or about May 5, 
2020 to October 19, 2020.  The spreadsheet shows the following:  
a.
Twenty-two employees from Western’s two Paychex
accounts had a combined pay of $235,166.51. 
b.
Twenty-nine employees from the -0968 account had
a combined pay of $121,425.01. 
c.
The total payroll was $356,591.52.
d.
Co-conspirator #1 was the highest paid employee
on the spreadsheet, with pay more than double the next highest 
employee of Western Distribution, LLC or Company A.  
75.
When the Bank asked Western Distribution, LLC for
details regarding its 2020 payroll on or about February 19, 
2021, Co-conspirator #2 responded three days later that “We have 
9 The government is conducting a handwriting analysis of the 
various signatures to determine if JOHANSSON forged his son’s 
signatures on the PPP loan application; the results are not yet 
available.  
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38 
3 different accounts with Paychex – different area / departments 
etc.”  Western Distribution, LLC did not disclose to the Bank 
that the 21 Company A Employees did not work at Western 
Distribution, LLC.  Nor did Western Distribution, LLC disclose 
to the Bank that Company A was not a department of Western 
Distribution, LLC but rather a separate company with a separate 
location and a separate business.  
76.
As of on or about June 29, 2021, the Bank was still
processing the loan forgiveness application.  On or about that 
date, I was told by the Bank that its review and approval of the 
forgiveness application were imminent. 
K.
Western Distribution, LLC’s Fraudulent Second PPP Loan
Application in March 2021
77.
On or about March 24, 2021, Western Distribution, LLC
applied for a second PPP loan (the “Second PPP Application”), 
also through the Bank.  The Second PPP Application included the 
following: 
a.
The amount requested was $231,527 (i.e., 2.5
times the purported Average Monthly Payroll of $92,611).  
b.
The company again claimed that it was an LLC,
rather than a corporation. 
c.
The owner was listed as Co-conspirator #1, who
was described as owning 100% of the company and listed a social 
security number matching Co-conspirator #1.   
d.
Question #3 stated: “Is the Applicant or any
owner of the Applicant an owner of any other business, or have 
common management (including a management agreement) with any 
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39 
other business?  If yes, list all such businesses (including 
their TINs if available) and describe the relationship on a 
separate sheet identified as addendum A.”  The response again 
was marked as “No,” and no addendum A was included.  
e.
Question #4 stated: “Is the applicant or any
individual owning 20% or more of the equity of the Applicant 
presently incarcerated or, for any felony, presently subject to 
an indictment, criminal information, arraignment, or other means 
by which formal criminal charges are brought in any 
jurisdiction?”  The response again was marked as “No” and the 
initials “CJ” were handwritten next to the response. 
f.
The application listed a series of certifications
to be made by the borrower, similar to the ones discussed above 
for Western Distribution, LLC’s first PPP loan application.  For 
example, “I certify that the information provided in this 
application and the information provided in all supporting 
documents and forms is true and correct in all material 
respects.”  The initials “CJ” were written next to each 
certification.  
g.
The application was signed by Co-conspirator #1,
whose title was listed as “Owner,” and dated on or about March 
24, 2021.  
h.
Documents submitted by Western Distribution, LLC
as part of the Second PPP Application reflected the same scheme 
on which the company based its loan forgiveness application two 
months earlier:  Western Distribution, LLC artificially inflated 
its payroll costs by including Company A’s employees who never 
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40 
worked for Western Distribution, LLC.  The Second PPP 
Application lumped together Paychex account -0968 (containing 
the 21 Company A Employees), which had $139,934 in payroll 
expenses in September and October 2020, with Western’s two other 
Paychex accounts.  The payroll expenses for account -0968 were 
higher than the payroll expenses for Western’s other Paychex 
accounts (due in part to the fact that JOHANSSON removed almost 
all of his employees – except his two sons – from the Paychex 
payroll for much of 2020). 
78. 
Based on the representations in the application, on or 
about March 24, 2021, the Bank issued a second PPP loan to 
Western Distribution, LLC in the amount of $231,527.   
79. 
Company A was likely ineligible to receive a second 
PPP loan because the pandemic did not cause the company the 
requisite twenty-five percent decline in revenues for any 
quarter in 2019 as compared to the same quarter in 2020.  Based 
on my training and experience, and my knowledge of this 
investigation, I believe that JOHANSSON represented to the Bank 
in the Second PPP Application that the Company A employees were 
actually employees of Western Distribution, LLC -- even though 
they were not -- because (1) he need to be consistent with the 
fraudulent PPP loan forgiveness application that he had caused 
Western Distribution, LLC to submit only months earlier, and (2) 
he knew that Company A was ineligible to obtain a second PPP 
loan on its own. 
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41 
L.
JOHANSSON’s Concurrent Fraud on the Department of
Transportation
80.
At the same time that JOHANSSON was claiming that
Western Distribution, LLC had dozens of employees for purposes 
of the PPP fraud, he was causing the company to make filings 
with the DOT that told a much different story.  
81.
As noted above, on or about April 25, 2019, JOHANSSON
filed a Form MCSA-1 to register Western Distribution, LLC with 
the FMCSA, in which he wrote that Western Distribution, LLC 
operated only one tanker truck.  Under penalty of perjury, in 
response to the question, “Do you currently have, or have had 
within the last 3 years of the date of filing this application, 
relationships involving common stock, common ownership, common 
management, common control or familial relationships with and 
FMCSA-regulated entities?,” JOHANSSON responded “No.”10  As a 
result of the filing of the Form MCSA-1, JOHANSSON obtained a 
DOT registration number for Western Distribution, LLC 
(#3278747).  
82.
The following chart shows relevant data from the MCS-
150 forms (MCS-150 forms are periodic updates required by FMCSA) 
submitted by Western Distribution, LLC (DOT #3278747) and 
Western Distribution, Inc. (DOT #3533763):  
10 Based on my discussions with colleagues at the DOT, 
Wholesale was a FMCSA-regulated entity because, at a minimum, it 
hauled jet fuel in interstate commerce.   
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42 
Date 
Named 
Entity 
DOT Number 
Signatory (and Title) 
Total 
Number of 
Drivers 
5/17/2019 
LLC 
3278747  
Carl Brad Johansson 
(CEO) 
1 
4/6/2020 
Corp. 
3278747 
Carl Johansson 
(President) 
3 
10/5/2020 
Corp. 
3278747 
Carl Johansson 
(Operations Manager) 
28 
11/2/2020 
Corp. 
3278747 
Carl Johansson 
(Operations Manager) 
1 
12/23/2020 
LLC 
3533763 
Carl Johansson (Admin. 
Manager) 
1 
12/29/2020 
Corp.  
3278747 
Carl Johansson 
(Operations Manager) 
1 
83.
The signatory on each of these forms certified that,
“[u]nder penalties of perjury, I declare that the information 
entered on this report is, to the best of my knowledge and 
belief, true, correct, and complete.”  Based on my training and 
experience, and my knowledge of this investigation, I believe 
that JOHANSSON was the signatory for each of these forms (i.e., 
rather than Co-conspirator #1, who has a very similar name).  
For example: 
a.
The person applying for a PIN number for the
FMCSA online portal for Western Distribution, Inc. was using the 
Western Distribution email account that Co-conspirator #2 
confirmed was JOHANSSON’s email account.  (Co-conspirator #2 
also confirmed that Co-conspirator #1 did not have an email 
account at Western Distribution.)   
b.
The email account listed on each of these MCS-150
Forms was JOHANSSON’s email account.  
c.
For more than a decade (first at National, and
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43 
then at Wholesale, and then at Western Distribution, LLC), 
JOHANSSON has commonly referred to himself as the Administrative 
Manager and Operations Manager of his companies, which is the 
same title used to describe “Carl Johansson” on the MCS-150 
forms.  
84. 
Based on my review of the Paychex payroll records for 
Western Distribution, LLC, and my training and experience, I 
believe that the information that JOHANSSON caused to be 
submitted on the MCS-150 Forms was false and misleading.  During 
the fall of 2020, for example, Western Distribution, LLC 
employed at least 17 drivers (excluding the Company A employees 
fraudulently transferred to Western Distribution, LLC’s Paychex 
account).  Likewise, Western Distribution, LLC – a trucking 
company that JOHANSSON repeatedly claimed to FMCSA had only one 
driver – reported approximately $1 million in “Gross Trucking 
Income” on its books for each quarter in 2020.   
85. 
In contrast, there is no Paychex account for Western 
Distribution, Inc., and I am not aware of any drivers employed 
by Western Distribution, Inc.  It is possible, even likely, that 
Western Distribution, Inc. has never carried out any actual 
trucking activities.  For example, the FMCSA database for 
roadside inspections (which tracks when trucks operated by a 
registered trucking company are inspected at certain roadside 
locations) does not contain a single inspection record for 
trucks operating under DOT #3278747.  Based on my discussions 
with colleagues at the DOT, I believe that it is unusual for a 
trucking company not to have any roadside inspections.  Based on 
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44 
the Paychex data and the lack of any roadside inspections for 
Western Distribution, Inc., I believe that JOHANSSON’s sworn 
claim that Western Distribution, Inc. employed 28 drivers on 
October 5, 2020 was false.   
86. 
As the chart above shows, sometime on or before 
December 23, 2020, JOHANSSON obtained a second DOT registration 
number for Western Distribution, LLC (DOT #3533763).  Based on 
my training and experience, and my discussions with colleagues 
at the DOT, there does not appear to be any legitimate reason 
why JOHANSSON would need two different DOT registration numbers 
for Western Distribution.  This appears to be a continuation of 
JOHANSSON’s decades-long practice of obtaining and maintaining 
multiple DOT registration numbers to evade regulators and, 
likely, secure insurance policies and clients that otherwise 
would have been unavailable to JOHANSSON due to his trucking 
companies’ history of safety violations.   
// 
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45 
V.
CONCLUSION
87.
Based on the foregoing, there is probable cause to
believe that JOHANSSON violated Title 18, United States Code, 
Sections 1344(2) and 2(b) (bank fraud and causing an act to be 
done) and Title 18, United States Code, Section 1349 (conspiracy 
to commit bank fraud).  
DANIEL DREYER, Special Agent 
Internal Revenue Service – 
Criminal Investigations  
Subscribed to and sworn before 
me on July ___, 2021. 
HONORABLE ALEXANDER F. MacKINNON 
UNITED STATES MAGISTRATE JUDGE 
2
Case 5:21-mj-00461-DUTY   Document 1   Filed 07/02/21   Page 48 of 48   Page ID #:48
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