Information — United States v. Bridgitte Keim

Record facts

U.S. District Court, Middle District of Florida · No. 8:21-cr-00370-CEH-JSS · Doc. 1 · 2021-11-29 · Docket on CourtListener

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Case 8:21-cr-00370-CEH-JSS Document1 Filed 11/29/21 Page 1 of 8 PagelD 1

UNITED STATES DISTRICT COURT
MIDDLE DISTRICT OF FLORIDA

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TAMPA DIVISION
UNITED STATES OF AMERICA
v. CASENO, 8:21 cK 299 CEN JSS
18 U.S.C. § 1344
BRIDGITTE KEIM

INFORMATION
The United States Attorney charges:

COUNT ONE
(Bank Fraud)

A. Introduction

At all times material to this Information:

1. Bridgitte Keim (“KEIM”) was a resident of the Middle District of
Florida.

2. The United States Small Business Administration (“SBA”) was an
executive-branch agency of the United States government that provided support to
entrepreneurs and small businesses. The mission of the SBA was to maintain and
strengthen the nation’s economy by enabling the establishment and viability of small
businesses and by assisting in the economic recovery of communities after disasters.

3. As part of this effort, the SBA enabled and provided for loans through
banks, credit unions, and other lenders. These loans had government-backed

guarantees.
Case 8:21-cr-00370-CEH-JSS Document1 Filed 11/29/21 Page 2 of 8 PagelD 2

4. The Coronavirus Aid, Relief, and Economic Security (“CARES”) Act
was a federal law enacted in or around March 2020 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 forgivable loans to small businesses for job
retention and certain other expenses, through a program referred to as the Paycheck
Protection Program (“PPP”).

5. 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. 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. These figures were used to calculate
the amount of money the small business was eligible to receive under the PPP. In
addition, businesses applying for a PPP loan were required to provide
documentation showing their payroll expenses.

6. PPP loan applications were processed by a participating lender. If a
PPP loan application was approved, the participating lender funded the PPP loan
using its own monies, which were 100% guaranteed by the SBA. Data from the

application, including information from the borrower, the total amount of the loan,
Case 8:21-cr-00370-CEH-JSS Document1 Filed 11/29/21 Page 3 of 8 PagelD 3

and the listed number of employees, was transmitted by the lender to the SBA in the
course of processing the loan.

7. PPP loan proceeds were required to be used for certain permissible
expenses, including payroll costs, mortgage interest, rent, and utilities. Under the
applicable PPP rules and guidance, the interest and principal on the PPP loan was
eligible for forgiveness if the business spent the loan proceeds on these expense items
within a designated period of time and used a certain portion of the loan towards
payroll expenses.

8. Bank 1 was a financial institution federally insured by the Federal
Deposit Insurance Corporation (“FDIC”) headquartered and with branches in the
Middle District of Florida and elsewhere. Bank 1 participated in the SBA’s PPP asa
lender and, as such, was authorized to lend funds to eligible borrowers under the
terms of PPP.

9. Bank 1 required prospective PPP borrowers to open and maintain a
bank account prior to PPP loan approval and funding.

B. The Scheme and Artifice

10. Starting in or about April 2020, and continuing at least through July

2021, in the Middle District of Florida, and elsewhere, the defendant,
BRIDGITTE KEIM,

and others did knowingly and intentionally execute, and attempt to execute, a

scheme and artifice to defraud Bank 1, a financial institution, and to obtain monies,

funds, credits, assets, and other property owned by, and under the custody and
AND oe gt

Case 8:21-cr-00370-CEH-JSS Document1 Filed 11/29/21 Page 4 of 8 PagelD 4

control of said financial institution, by means of materially false and fraudulent
pretenses, representations and promises.

Cc. Manner and Means of the Scheme

11. The manner and means by which the defendant and others sought to
accomplish the scheme and artifice included, among others, the following:

a. It was part of the scheme and artifice that KEIM would and did
solicit family members and friends to participate in the SBA PPP loan program.

b. It was further part of the scheme and artifice that KEIM would
and did tell her family members and friends that she would prepare all necessary PPP
loan paperwork knowing full well that the vast majority of the applicants did not
have existing businesses.

Cc. It was further part of the scheme and artifice that KEIM would
and did create fictitious businesses for the individuals she recruited in order for the
applicants to purportedly qualify for SBA guaranteed PPP loans at Bank 1.

d. It was further part of the scheme and artifice that KEIM would
and did create email addresses for the applicants she recruited for the purpose of
submitting PPP documents to Bank 1 and communicating with Bank 1 loan officers
to give the false appearance to the loan officers that they were communicating with
the actual prospective borrower, not KEIM.

e. It was further part of the scheme and artifice that KEIM would
and did knowingly prepare and cause to be prepared fraudulent PPP loan

applications in the names of the individuals she recruited to Bank 1.

4
Case 8:21-cr-00370-CEH-JSS Document 1 Filed 11/29/21 Page 5 of 8 PagelD 5

f, It was further part of the scheme and artifice that KEIM would
and did submit and cause to be submitted fraudulent PPP loan applications on behalf
of relatives or friends containing material false, fraudulent, and misleading
statements to Bank 1 and SBA.

g. It was further part of the scheme and artifice that KEIM would
and did knowingly prepare, cause to be prepared, submit, and cause to be submitted
fraudulent payroll documentation for the fictitious businesses she created to qualify
the PPP loan applicants she recruited.

h. It was further part of the scheme and artifice that, after
submitting the false and fraudulent PPP loan applications, KEIM would and did
send text messages containing the names of the fictitious business names, false
financial information, and the email addresses she created to the relatives she
recruited so that these individuals could answer any questions from bank employees
about the loan applications.

i. It was further part of the scheme and artifice that KEIM would
and did falsely represent that all SBA PPP Loan proceeds would be used by the
individuals she filed loan applications for only for business related purposes as
specified in the loan application.

j. It was further part of the scheme and artifice that KEIMS’s
materially false, fraudulent, and misleading representations would and did cause

Bank 1 to approve the PPP loan applications and Bank 1 to issue approximately
Case 8:21-cr-00370-CEH-JSS Document1 Filed 11/29/21 Page 6 of 8 PagelD 6

$817,560.56.in PPP funds, which Bank I then deposited into accounts of the
individuals KEIM recruited.

k. It was further part of the scheme and artifice that defendant
KEIM would and did use and cause the PPP funds to be used for unauthorized
purposes and for her own personal enrichment.

1. It was further part of the scheme and artifice that KEIM would
and did misrepresent, hide, and conceal, and cause to be misrepresented, hidden, and
concealed, the purpose of acts performed in furtherance of the scheme.

D. Execution of the Scheme
12. Onor about March 4, 2021, in the Middle District of Florida and
elsewhere, the defendant,
BRIDGITTE KEIM,
knowingly and intentionally executed and attempted to execute the aforesaid scheme
and artifice to defraud, by preparing and submitting a fraudulent PPP loan
application containing material false statements in the name of borrower G.H., in
order to obtain loan proceeds from Bank 1, a bank insured by the FDIC, which loan
was guaranteed by the SBA and which proceeds were deposited into an account at
Bank 1 that the defendant accessed and withdrew funds from.

All in violation of 18 U.S.C. §§ 1344 and 2.
Case 8:21-cr-00370-CEH-JSS Document1 Filed 11/29/21 Page 7 of 8 PagelD 7

FORFEITURE

1. The allegations contained in Count One is incorporated by reference for
the purpose of alleging forfeiture pursuant to 18 U.S.C. §§ 982(a)(1) and (a)(2)(A).

2. Upon conviction of a violation of 18 U.S.C § 1344, the defendant,

BRIDGITTE KEIM,

shall forfeit to the United States, pursuant to 18 U.S.C. § 982(a)(2)(A), any property
constituting, or derived from, proceeds obtained directly or indirectly, as a result of
such violation.

2. The property to be forfeited includes, but is not limited to, an order of
forfeiture in the amount of approximately $7,500, which represents the proceeds

obtained from the offenses; and

3. If any of the property described above, as a result of any act or omission
of the defendant:
a. cannot be located upon the exercise of due diligence;

b. has been transferred or sold to, or deposited with, a third party;

c. has been placed beyond the jurisdiction of the Court;

d. has been substantially diminished in value; or
e. has been commingled with other property which cannot be
divided without difficulty,
Case 8:21-cr-00370-CEH-JSS Document1 Filed 11/29/21 Page 8 of 8 PagelD 8

the United States shall be entitled to forfeiture of substitute property under the

provisions of 21 U.S.C § 853(p), as incorporated by 18 U.S.C § 982(b)(1).

KARIN HOPPMANN

Acting United States Aféorn
By: 4 C

ChristSpher Poor
Special Assistant United States Attorney

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Jay G. Trezevant
Assistant United States Attorney
Chief, Economic Crimes Section

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