Indictment — United States v. Golden-Larimore, et al.

Record facts

U.S. District Court, Western District of Missouri · No. 4:23-cr-00098-BCW · Doc. 1 · 2023-04-26 · Docket on CourtListener

Full text

IN THE UNITED STATES DISTRICT COURT FOR THE 
WESTERN DISTRICT OF MISSOURI 
WESTERN DIVISION 
 
UNITED STATES OF AMERICA, 
 
 
 
Plaintiff, 
 
 
v. 
 
RENETTA GOLDEN-LARIMORE (01), 
[DOB:  11/18/1968] 
 
DON A. BAKER (02), 
[DOB:  11/26/1975] 
 
STEPHAN BOOTH (03), 
[DOB:  02/22/1983] 
 
CAMERON P. HENDERSON (04), 
[DOB:  01/09/1996] 
 
CANDACE E. HILL-WILLIAMS (05), 
[DOB:  01/08/1998] 
 
REISJON LARIMORE (06), 
[DOB:  07/29/1997] 
 
ROGER LARIMORE (07), 
[DOB:  02/10/1996] 
 
TEIARA M. MERCER (08), 
[DOB:  03/21/2000] 
 
PADGIT L. SMITH (09), 
[DOB:  08/27/1974] 
 
JOSEPH VALDIVIA III (10), 
[DOB:  10/02/1977] 
 
SALVADOR VALDIVIA (11), 
[DOB:  01/02/1982] 
 
MONE’Y C. WOODS (12), 
[DOB:  06/12/2001] 
 
 
 
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 - THIRTEEN: 
(Wire Fraud) 
18 U.S.C. § 1343 
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 
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DEFENDANT NO. 
DEFENDANT NAME 
COUNTS CHARGED 
1 
RENETTA GOLDEN-LARIMORE 
1 - 13, and Forfeiture 
Allegation 
2 
DON A. BAKER 
1 & 3, and Forfeiture 
Allegation 
3 
STEPHAN BOOTH 
1 & 4, and Forfeiture 
Allegation 
4 
CAMERON P. HENDERSON 
1 & 5, and Forfeiture 
Allegation 
5 
CANDACE E. HILL-WILLIAMS 
1 & 6, and Forfeiture 
Allegation 
6 
REISJON LARIMORE 
1 & 7, and Forfeiture 
Allegation 
7 
ROGER LARIMORE 
1 & 8, and Forfeiture 
Allegation 
8 
TEIARA M. MERCER 
1 & 9, and Forfeiture 
Allegation 
9 
PADGIT L. SMITH 
1 & 10, and Forfeiture 
Allegation 
10 
JOSEPH VALDIVIA III 
1 & 11, and Forfeiture 
Allegation 
11 
SALVADOR VALDIVIA 
1 & 12, and Forfeiture 
Allegation 
12 
MONE’Y C. WOODS 
1 & 13, and Forfeiture 
Allegation 
 
I N D I C T M E N T 
 
THE GRAND JURY CHARGES THAT: 
 
COUNT ONE 
 
THE GRAND JURY CHARGES THAT: 
At all times material to this Indictment: 
Introduction 
1. 
Beginning no later than on or about February 2021, and continuing until 
at least May 2022, in Jackson County, within the Western District of Missouri and 
elsewhere, RENETTA GOLDEN-LARIMORE (GOLDEN-LARIMORE); DON A. BAKER; 
STEPHAN 
BOOTH; 
CAMERON 
P. 
HENDERSON; 
CANDACE HILL-WILLIAMS; 
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REISJON LARIMORE; ROGER LARIMORE; TEIARA M. MERCER; PADGIT L. SMITH; 
JOSEPH VALDIVIA III; SALVADOR VALDIVIA; and MONE’Y WOODS, 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 the 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. 
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”). 
 
 
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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. 
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. 
 
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6. 
Individuals who operated a business under a “sole proprietorship” business 
structure were also eligible for a PPP loan. To qualify for such 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. 
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; 
 
Itria Ventures LLC was a national, non-bank, direct commercial lender based in New York 
that funded PPP loans. 
 
 
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Capital Plus Financial, LLC was a CDFI community development financial institution 
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 February 2021, and continuing through on or about 
May 2022, in Jackson County, within the Western District of Missouri and elsewhere, the 
defendants RENETTA GOLDEN-LARIMORE; DON A. BAKER; STEPHAN BOOTH; 
CAMERON P. HENDERSON; CANDACE HILL-WILLIAMS; REISJON LARIMORE; 
ROGER LARIMORE; TEIARA M. MERCER; PADGIT L. SMITH; JOSEPH VALDIVIA III; 
SALVADOR VALDIVIA; and MONE’Y WOODS 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 furtherance thereof transmitted and caused to be transmitted interstate 
wire communications. 
Contrary to the provisions of 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 exit in 2019. 
 
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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. 
On or about the dates listed below, GOLDEN-LARIMORE electronically created loan 
accounts, submitted false PPP loan applications through blueacorn, 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. 
02/11/2021 GOLDEN-LARIMORE 
75.81.141.44 Itria Ventures, LLC– 
New York 
$20,833 
b. 
04/16/2021 DON A. BAKER 
75.81.141.44 Prestamos – Arizona 
$20,832 
 
 
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c. 
05/02/2021 STEPHAN BOOTH 
75.81.141.44 Prestamos – Arizona 
$20,832 
d. 
05/21/2021 CAMERON P. 
HENDERSON 
75.81.141.44 Prestamos – Arizona 
$20,832 
e. 
05/12/2021 CANDACE HILL-
WILLIAMS  
75.81.141.44 Prestamos – Arizona 
$20,832 
f. 
03/11/2021 REISJON LARIMORE 
75.81.141.44 Itria Ventures, LLC – 
New York 
$20,833 
g. 
03/20/2021 ROGER LARIMORE 
75.81.141.44 Capital Plus Financial, 
LLC, Texas 
$20,832 
h. 
05/02/2021 TEIARA M. MERCER 
75.81.141.44 Prestamos – Arizona 
$20,832 
i. 
04/16/2021 PADGIT L. SMITH 
75.81.141.44 Prestamos – Arizona 
$20,832 
j. 
05/10/2021 JOSEPH VALDIVIA III 
75.81.141.44 Prestamos – Arizona 
$20,832 
k. 
05/10/2021 SALVADOR 
VALDIVIA 
75.81.141.44 Prestamos – Arizona 
$20,832 
l. 
05/10/2021 MONE’Y WOODS 
75.81.141.44 Prestamos – Arizona 
$20,832 
 
Contrary to the provisions of Title 18, United States Code, Section 1349. 
COUNTS TWO -THIRTEEN 
16. 
Paragraphs 1 through 15 of the Indictment are hereby realleged and incorporated 
into Counts Two through Thirteen. 
Count Two 
17. 
On or about February 13, 2021, defendant RENETTA GOLDEN-LARIMORE 
completed and sent an application and supporting documents to blueacorn to apply for a PPP loan 
under the CARES Act for her business Golden R Creations.  
18. 
The 
application 
and 
supporting 
documents 
stated 
that 
the defendant 
RENETTA GOLDEN-LARIMORE was a sole proprietor of a business which had an average 
monthly payroll of $10,000. The supporting documents also included a Form 1040 SCHEDULE C 
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for 2020, which listed gross receipts or sales of $225,001, business expenses of $123,591 and 
a profit of $101,410. 
19. 
In fact, the defendant RENETTA GOLDEN-LARIMORE did not file a 2020 tax 
return for Golden R Creations and her personal income tax return did not report income and 
expenses that were claimed in the loan application. 
20. 
On or about the date set forth below, in Kansas City, Missouri, in the Western 
District of Missouri, the defendant RENETTA GOLDEN-LARIMORE, 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 
03/11/2021 
Itria Ventures, LLC 
Navy Federal Credit Union 
$20,833.33 
 
Contrary to the provisions of Title 18, United States Code, Section 1343. 
 
Count Three 
21. 
On or about April 16, 2021, defendant RENETTA GOLDEN-LARIMORE, aided 
and abetted by defendant DON BAKER, completed and sent an application and supporting 
documents to blueacorn to apply for a PPP loan under the CARES Act for BAKER’s business. 
22. 
The application and supporting documents stated that the defendant BAKER was a 
sole proprietor of a business which had gross receipts or sales of $144,080 and a profit of $99,982. 
A 2019 tax return for the defendant Baker listing the same amounts on Form Schedule C was 
submitted as part of the application. 
 
 
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23. 
In fact, the defendant BAKER did not have a business in 2019 with those gross 
receipts and profit and BAKER did not file a personal 2019 tax return. 
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 DON BAKER, 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 
06/07/2021 
Prestamos CDFI 
J.P. Morgan Chase 
$20,832 
 
Contrary to the provisions of Title 18, United States Code, Section 1343. 
 
Count Four 
24. 
On or about May 2, 2021, defendant RENETTA GOLDEN-LARIMORE, aided 
and abetted by defendant STEPHAN BOOTH, completed and sent an application and supporting 
documents to blueacorn to apply for a PPP loan under the CARES Act for BOOTH’s “landscaping 
services” business. 
25. 
The 
application 
and 
supporting 
documents 
stated 
that 
the defendant 
STEPHAN BOOTH  was a sole proprietor of a business which had gross receipts or sales of 
$144,080 and a profit of $99,982. As part of the application, a 2019 tax return for the defendant 
STEPHAN BOOTH was submitted listing gross receipts of $225,001 and a profit of $101,410 on 
Form Schedule C. 
26. 
In fact, the defendant BOOTH did not have a business in 2019 with those gross 
receipts and profit and BOOTH did not file a personal 2019 tax return. 
 
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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 STEPHAN BOOTH, 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 
06/07/2021 
Prestamos CDFI 
J.P. Morgan Chase 
$20,832 
 
Contrary to the provisions of Title 18, United States Code, Section 1343. 
 
Count Five 
27. 
On or about May 21, 2021, defendant RENETTA GOLDEN-LARIMORE, aided 
and abetted by defendant CAMERON HENDERSON, completed and sent an application and 
supporting documents to Blueacorn to apply for a PPP loan under the CARES Act for 
HENDERSON’s business. 
28. 
The application and supporting documents stated that the defendant HENDERSON 
was a sole proprietor of a business that was established on February 5, 2018, and which had gross 
receipts or sales of $144,080 and a profit of $99,982. As part of the application, a 2019 Form 
Schedule C was submitted listing the same gross receipts and profit. 
29. 
In fact, the defendant HENDERSON did not have a business in 2019 with those 
gross receipts and profit. Defendant HENDERSON’s personal 2019 tax return did not report 
income and expenses that were claimed in the loan application. 
 
 
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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 CAMERON 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 
5 
06/11/2021 
Prestamos CDFI 
J.P. Morgan Chase 
$20,832 
 
Contrary to the provisions of Title 18, United States Code, Section 1343. 
 
COUNT SIX 
30. 
On or about May 12, 2021, defendant RENETTA GOLDEN-LARIMORE, aided 
and abetted by defendant CANDACE HILL-WILLIAMS, completed and sent an application and 
supporting documents to blueacorn to apply for a PPP loan under the CARES Act for 
HILL-WILLIAMS’ business. 
31. 
The 
application 
and 
supporting 
documents 
stated 
that 
the defendant 
HILL-WILLIAMS was a sole proprietor of a business that was established on August 6, 2018, and 
which had gross receipts or sales of $144,080 and a profit of $99,982. As part of the application, 
a 2019 Form Schedule C was submitted listing the same gross receipts and profit. 
32. 
In fact, the defendant HILL-WILLIAMS did not have a business in 2019 with those 
gross receipts and profit. HILL-WILLIAMS’ personal 2019 tax return did not report income and 
expenses that were claimed in the loan application. 
 
 
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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 CANDACE HILL-WILLIAMS, 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 
06/04/2021 
Prestamos CDFI 
Wells Fargo 
$20,832 
 
Contrary to the provisions of Title 18, United States Code, Section 1343. 
 
COUNT SEVEN 
33. 
On or about March 20, 2021, defendant RENETTA GOLDEN-LARIMORE, aided 
and abetted by defendant REISJON LARIMORE, completed and sent an application and 
supporting documents to blueacorn to apply for a PPP loan under the CARES Act for 
Larimore Landscaping. 
34. 
The 
application 
and 
supporting 
documents 
stated 
that 
the defendant 
REISJON LARIMORE was a sole proprietor of a business was established on July 30, 2018, and 
that had gross income of $120,000. As part of the application, a 2019 tax return was submitted 
with a Form Schedule C listing gross receipts of $225,001 and a profit of $101,410. 
35. 
In fact, the defendant REISJON LARIMORE did not have a business in 2019 with 
those gross receipts and profit. REISJON LARIMORE’s personal 2019 tax return did not report 
income and expenses that were claimed in the loan application. 
 
 
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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 REISJON LARIMORE, 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 
04/08/2021 
Itria Ventures, LLC 
Navy Federal Credit Union 
$20,833 
 
Contrary to the provisions of Title 18, United States Code, Section 1343. 
COUNT EIGHT 
36. 
On or about March 20, 2021, defendant RENETTA GOLDEN-LARIMORE, aided 
and abetted by defendant ROGER LARIMORE, completed and sent an application and supporting 
documents to Blueacorn to apply for a PPP loan under the CARES Act for his business “Bro’s and 
Holes”. 
37. 
The 
application 
and 
supporting 
documents 
stated 
that 
the defendant 
REISJON LARIMORE was a sole proprietor of a business was established April 6, 2018, and that 
had gross income of $125,001. As part of the application, a 2019 Form Schedule C was submitted 
with listing gross receipts of $125,001 and a profit of $67,891. 
38. 
In fact, the defendant, ROGER LARIMORE did not have a business in 2019 with 
those gross receipts and profit. ROGER LARIMORE’s personal 2019 tax return did not report 
income and expenses that were claimed in the loan application. 
 
 
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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 ROGER LARIMORE, 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 
8 
May 18, 2021 
Capital Plus 
Financial LLC 
J.P. Morgan Chase 
$20,832 
 
Contrary to the provisions of Title 18, United States Code, Section 1343. 
 
COUNT NINE 
39. 
On or about May 19, 2021, defendant RENETTA GOLDEN-LARIMORE, aided 
and abetted by defendant TEIARA MERCER, completed and sent an application and supporting 
documents to blueacorn apply for a PPP loan under the CARES Act for her business. 
40. 
The 
application 
and 
supporting 
documents 
stated 
that 
the defendant 
TEIARA MERCER was a sole proprietor of a business was established January 1, 2020, and that 
had gross receipts of $144,080 and net income of $99,982. 
41. 
In fact, the defendant TEIARA MERCER did not have a business in 2020 with 
those gross receipts and profit and TEIARA MERCER did not file a personal 2019 or 2020 
tax return. 
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 TEIARA MERCER, having devised and intended to devise a scheme to obtain 
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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 
9 
06/11/2021 
Prestamos CDFI 
J.P. Morgan Chase  
$20,832 
 
Contrary to the provisions of Title 18, United States Code, Section 1343. 
COUNT TEN 
42. 
On or about April 16, 2021, defendant RENETTA GOLDEN-LARIMORE, aided 
and abetted by defendant PADGIT SMITH, completed and sent an application and supporting 
documents to blueacorn to apply for a PPP loan under the CARES Act for her business. 
43. 
The 
application 
and 
supporting 
documents 
stated 
that 
the defendant 
PADGIT SMITH was a sole proprietor of a business was established February 1, 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 listing the same amounts.  
44. 
In fact, the defendant, PADGIT SMITH did not have a business in 2019 with those 
gross receipts and profit. PADGIT SMITH’s personal 2019 tax return did not report income and 
expenses that were claimed in the loan application. 
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 PADGIT 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 
Case 4:23-cr-00098-BCW     Document 1     Filed 04/26/23     Page 16 of 22

17 
transmitted by means of wire communication in interstate commerce the signals and sounds 
described below: 
Count 
Date 
Wire From 
To 
Amount 
10 
07/12/2021 
Prestamos CDFI 
J.P. Morgan Chase 
$20,832 
 
Contrary to the provisions of Title 18, United States Code, Section 1343. 
 
COUNT ELEVEN 
45. 
On or about May 11, 2021, defendant RENETTA GOLDEN-LARIMORE, aided 
and abetted by defendant JOSEPH VALDIVIA III, completed and sent an application and 
supporting documents to blueacorn to apply for a PPP loan under the CARES Act for his business 
-a full-service restaurant. 
46. 
The 
application 
and 
supporting 
documents 
stated 
that 
the defendant 
JOSEPH VALDIVIA III was a sole proprietor of a business was established February 5, 2018, and 
that had gross receipts of $141,080 and net income of $99,982. As part of the application, a 2019 
tax return with a Form Schedule C was submitted listing gross receipts of $144,080 and a net 
income of $99,982. 
47. 
In fact, the defendant, JOSEPH VALDIVIA III did not have a business in 2019 
with those gross receipts and profit. JOSEPH VALDIVIA’s personal 2019 tax return did not report 
income and expenses that were claimed in the loan application. 
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 JOSEPH VALDIVIA III, 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 
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18 
transmitted by means of wire communication in interstate commerce the signals 
and sounds described below: 
Count 
Date 
Wire From 
To 
Amount 
11 
06/08/2021 
Prestamos CDFI 
J.P. Morgan Chase 
$20,832 
 
Contrary to the provisions of Title 18, United States Code, Section 1343. 
COUNT TWELVE 
48. 
On or about May 10, 2021, defendant RENETTA GOLDEN-LARIMORE, aided 
and abetted by defendant SALVADOR VALDIVIA, completed and sent an application and 
supporting documents to blueacorn to apply for a PPP loan under the CARES Act for his business 
- a landscaping business. 
49. 
The 
application 
and 
supporting 
documents 
stated 
that 
the defendant 
JOSEPH VALDIVIA was a sole proprietor of a business was established February 5, 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 listing the same amounts. 
50. 
In fact, the defendant, SALVADOR VALDIVIA did not have a business in 2019 
with those gross receipts and profit and SALVADOR VALDIVIA did not file a personal 2019 tax 
return. 
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 SALVADOR VALDIVIA, 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, 
 
 
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19 
caused to be transmitted by means of wire communication in interstate commerce the 
signals and sounds described below: 
Count 
Date 
Wire From 
To 
Amount 
12 
06/04/2021 
Prestamos CDFI 
J.P. Morgan Chase 
$20,832 
 
Contrary to the provisions of Title 18, United States Code, Section 1343. 
 
COUNT 13 
51. 
On or about May 11, 2021, defendant RENETTA GOLDEN-LARIMORE, aided 
and abetted by defendant MONE’Y WOODS, completed and sent an application and supporting 
documents to blueacorn to apply for a PPP loan under the CARES Act for her business - beautician 
services. 
52. 
The 
application 
and 
supporting 
documents 
stated 
that 
the defendant 
MONE’Y WOODS was a sole proprietor of a business that was established February 25, 2018, 
and that had gross receipts of $141,080 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. 
53. 
In fact, the defendant, MONE Y WOODS did not have a business in 2019 with 
those gross receipts and profit and MONE’Y WOODS did not file a personal 2019 tax return. 
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 MONE’Y WOODS, 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: 
 
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20 
Count 
Date 
Wire From 
To 
Amount 
13 
06/04/2021 
Prestamos CDFI 
J.P. Morgan Chase 
$20,832 
 
Contrary to the provisions of Title 18, United States Code, Section 1343. 
FORFEITURE ALLEGATION ONE 
 
54. 
The statements and allegations contained in counts one through 13 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. 
55. 
As a result of the offenses alleged in counts one through 13 of the Indictment, 
defendant RENETTA GOLDEN-LARIMORE, 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 one through 13 of this Indictment, including, but not limited 
to, the following property: a money judgment in the amount of at least $75,833.00. 
Substitute Assets 
56. 
If any of the property described in the above paragraph, as a result of any act or 
omission of the defendant, 
(A) 
cannot be located upon the exercise of due diligence; 
 
(B) 
has been transferred 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; 
 
 
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21 
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 defendant up to the value of the 
forfeitable property. 
FORFEITURE ALLEGATION TWO 
57. 
The statements and allegations contained in counts one through 13 of this Indictment are 
realleged and incorporated by reference for purposes of alleging forfeiture to the United States, 
pursuant to the provisions of Title 18, United States Code, Section 981(a)(1)(C) and Title 28, 
United States Code, Section 2461(c). 
58. 
As a result of the offenses alleged in counts one through 13 of the Indictment, 
defendants 
DON 
A. 
BAKER, 
STEPHAN 
BOOTH, 
CAMERON P. HENDERSON, 
CANDACE HILL-WILLIAMS, 
REISJON 
LARIMORE, 
ROGER 
LARIMORE, 
TEIARA M. MERCER, PADGIT L. SMITH, JOSEPH VALDIVIA III, SALVADOR VALDIVIA, 
and MONE’Y WOODS 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 13 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 
59. 
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; 
 
 
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22 
(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. 
 
 
04/25/2023 
 
 
 
 
 
/s/ Kimberley Deardorff 
 
 
 
DATE 
FOREPERSON OF THE GRAND JURY 
 
 
/s/ Paul Becker 
 
 
Paul S. Becker 
Assistant United States Attorney 
Western District of Missouri 
Case 4:23-cr-00098-BCW     Document 1     Filed 04/26/23     Page 22 of 22

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