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Government’s Supplement in Support of Its Notice and Motion to Admit Evidence as Intrinsic Evidence or, in the Alternative, Pursuant to Federal Rule of Evidence 404(B) — United States v. Adams (Dkt. 200, D.D.C.)
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The government's supplement in support of its notice and motion to admit evidence as intrinsic evidence or, alternatively, under Federal Rule of Evidence 404(b), in United States v. Roberto Adams, Criminal No. 21-CR-625 (APM), in the U.S. District Court for the District of Columbia, filed March 25, 2026 as Document 200 by Assistant U.S. Attorneys Caelainn Carney and Sarah C. Santiago. It supplements the motion at ECF 189. The government identifies three areas of evidence: Adams' receipt of the first loan proceeds and their depletion in his bank accounts; inconsistencies between his Economic Injury Disaster Loan and tax submissions and the loan application, especially on ownership percentages; and his later application to the Seattle Police Department, a fake SuperKlean invoice and fraudulent business expenses.
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Filed March 25, 2026 in Roberto Adams; one of 4 filings from this case.
Record facts
| Court | U.S. District Court for the District of Columbia |
|---|---|
| Filed | 2026-03-25 |
Cite this document
“Government’s Supplement in Support of Its Notice and Motion to Admit Evidence as Intrinsic Evidence or, in the Alternative, Pursuant to Federal Rule of Evidence 404(B) — United States v. Adams (Dkt. 200, D.D.C.).”
U.S. District Court for the District of Columbia, No. 1:21-cr-00625, Doc. 200, filed 2026-03-25. Archived at Pandemic Darlings, https://pandemicdarlings.com/court-filings/us-v-roberto-adams/2026-03-25-government-s-supplement-in-support-of-its-notice-and-motion-dkt-200/
, SHA-256 4d1919af4a64fa0d3ab3eebc6e7c65e3cbf22f6c73ee49e0d2713278caa003c9.Full text
Case 1:21-cr-00625-APM Document 200 Filed 03/25/26 Page 1 of 11
UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA
UNITED STATES OF AMERICA : CRIMINAL NO. 21-CR-625 (APM)
:
v. :
:
ROBERTO ADAMS, :
:
Defendant. :
GOVERNMENT’S SUPPLEMENT IN SUPPORT OF ITS NOTICE AND MOTION TO
ADMIT EVIDENCE AS INTRINSIC EVIDENCE OR, IN THE ALTERNATIVE,
PURSUANT TO FEDERAL RULE OF EVIDENCE 404(B)
The United States of America hereby files the instant Supplement in further support of its
notice and motion to admit evidence as intrinsic or pursuant to Fed. R. Evid. 404(b). ECF 189. 1
There are three principle areas of evidence that the government seeks to introduce at trial: (1)
Adams’ receipt of the first loan proceeds and the depletion of the proceeds as reflected in his bank
account balances, (2) the inconsistencies between the Economic Injury Disaster Loan (EIDL) and
tax submissions with the loan application, particularly regarding ownership percentages, and (3)
Adams’ actions following the depletion of the loan funds in applying to the Seattle Police
Department and in making a fake SuperKlean invoice and identifying fraudulent business
expenses. Pursuant to the Court’s Order, the Government provides the chart below regarding the
exhibits the Government anticipates it would seek to admit in connection with its motion. ME
1/30/26. The chart includes the exhibit number, a description of the item, and the specific
purpose(s) under Fed. R. Evid. 404(b) that allows for the introduction of the evidence.
1
“ECF #” refers to the docket entries for this case at the indicated number. “ME” refers to the
minute entries for the docket in this case.
Case 1:21-cr-00625-APM Document 200 Filed 03/25/26 Page 2 of 11
POTENTIAL EXHIBITS
Exhibit 2 Description 404(b) Purpose
2 SuperKlean Intake Application Demonstrates the defendant’s knowledge of the
(EIDL) loan process for pandemic relief. Moreover, the
contradictory information contained in Adams’
EIDL application, his tax forms, and his second
PPP loan application establishes Adams’ intent
on the second PPP loan application showing a
lack of mistake or accident.
10 Rapid Finance Application See explanation above.
(EIDL)
11 Outside Employment Records This contradicts Adams’ assertion that
SuperKlean existed in the way it was portrayed.
It demonstrates Adams’ intent to fraudulently
claim that he had a business at the time he
applied for the second PPP loan.
13 BlueVine Database Records for This exhibit contains information provided by
Roberto Adams BlueVine regarding Adams’ PPP application. It
demonstrates knowledge of how the process
worked and a lack of accident or mistake in
seeking a second loan.
14 SBA Form 1050, Settlement The disbursement of the first PPP loan funds is
Sheet 7.31.20 necessary to show that Adams received the
money. This goes directly to his certification on
his second PPP application that he received and
spent the funds for appropriate purposes. The
evidence goes to his intent on the second PPP
application and demonstrates a lack of mistake
or accident in the use of the second disbursement
of funds.
2
The Government uses the Exhibit Numbers that were used during the August 2023 trial. All but
one of the referenced exhibits were admitted into evidence at the first trial. For ease of reference,
the government has upload the exhibits to USAfx for review.
2
Case 1:21-cr-00625-APM Document 200 Filed 03/25/26 Page 3 of 11
Exhibit 2 Description 404(b) Purpose
15 Paycheck Protection Program Shows that first loan was applied for and
Borrower Application provides context for the second draw. This
demonstrates the defendant’s knowledge of the
PPP process showing the lack of accident or
mistake in seeking to apply for a second loan.
16 SBA loan note 7.31.20 Same as above.
17 Authorization to release Same as above.
information 7.31.20
18 Resolution to borrow 7.31.20 Same as above.
21 Maryland Driver’s license photo Same as above.
[as part of first loan application]
22 Schedule C for SuperKlean Same as above. In addition, the contradictory
information contained in Adams’ EIDL
application, his tax forms, and his second PPP
loan application establishes Adams’ intent on the
second PPP loan application showing a lack of
mistake or accident.
28 Paycheck protection program Shows that first loan was applied for and
borrower application 7.31.20 provides context for the second draw. This
demonstrates the defendant’s knowledge of the
PPP process showing the lack of accident or
mistake in seeking to apply for a second loan.
36 CrossRiver Database Records Same as above.
37 Loan Forgiveness Application Same as above. In addition, this exhibit shows
8.5.21 defendant’s knowledge and understanding
regarding loan process as it postdates his misuse
of the first loan’s funds and goes toward his
knowledge and lack of mistake or accident in the
certification on his second loan application that
he used the first loan funds for an approved
purpose.
3
Case 1:21-cr-00625-APM Document 200 Filed 03/25/26 Page 4 of 11
Exhibit 2 Description 404(b) Purpose
38 Letter of loan satisfaction. Same as above.
8.18.21
41 Federal Tax Return for 2020, This exhibit contains inconsistencies between
Certified the EIDL and loan application. It is probative
that SuperKlean did not exist as represented in
second draw application, which incorporated
Schedule C from first application and goes to a
lack of mistake.
42 IRS Certification of Lack of Same as above.
Records SuperKlean
46 Federal Income Tax Return Same as above.
2020- from Buckmon
48 U.S. Return of Partnership Same as above. This exhibit specifically states
Income- Form 1065 that SuperKlean was created on June 25, 2020,
but the second draw application has an
affirmation that the business existed before
February 15, 2020.
71 BOA Statement 7.25.20-8.24.20 Shows disbursement of the first loan. The
disbursement of the first PPP loan funds is
necessary to show that Adams received the
money. This goes directly to his certification on
his second PPP application that he received and
spent the funds for appropriate purposes. The
evidence goes to his intent on the second PPP
application and demonstrates a lack of mistake
or accident in the use of the second disbursement
of funds.
72 BOA 8.25.20- 9.23.20 Shows use of funds from the first loan, including
expenses for Las Vegas. The disbursement of
the first PPP loan funds is necessary to show that
Adams received the money. This goes directly
to his certification on his second PPP application
that he received and spent the funds for
appropriate purposes. The evidence goes to his
intent on the second PPP application and
4
Case 1:21-cr-00625-APM Document 200 Filed 03/25/26 Page 5 of 11
Exhibit 2 Description 404(b) Purpose
demonstrates a lack of mistake or accident in the
use of the second disbursement of funds.
89 Email from Bunche to Adams Shows context that first loan was submitted.
regarding her services This demonstrates Adams’ knowledge of the
loan process and a lack of mistake or accident in
applying for the second loan application.
90 Application information sent Shows context that first loan was submitted.
from Adams to Bunche This demonstrates Adams’ knowledge of the
loan process and a lack of mistake or accident in
applying for the second loan application.
91 Application information sent Same as above.
from Adams to Bunche
92 Application information sent Same as above.
from Adams to Bunche
93 Email from BlueVine to Adams Same as above.
that account was created
94 Application information sent Same as above.
from Adams to Bunche
95 Email from BlueVine to Adams Same as above.
that PPP loan was submitted
96 Email from BlueVine to Adams Same as above.
that PPP offer was extended
97 Email from BlueVine to Adams Same as above.
regarding PPP DocuSign
98 Invoice from Bunche to Adams Same as above.
99 Payment of Invoice by Adams to Same as above.
Bunche
5
Case 1:21-cr-00625-APM Document 200 Filed 03/25/26 Page 6 of 11
Exhibit 2 Description 404(b) Purpose
105 3 SuperKlean Cleaning Invoice This contradicts Adams’ assertion that
from 9.20.21 SuperKlean existed in the way it was portrayed.
It demonstrates Adams’ intent to fraudulent
claim that he had a business at the time he
applied for the second PPP loan.
119 Search Warrant Photo- Legal This exhibit is offered to show that there were
Zoom Binder no changes to SuperKlean’s ownership. It goes
to the inconsistencies in the EDIL, tax, and
second loan applications which demonstrate
Adams’ intent, knowledge, and lack of mistake
or accident in his second draw application.
129.2 Seattle Police Department This provides context for the defendant’s
Application statement to Seattle Police Department and
demonstrates that he knew of and understood the
purpose of the PPP program.
130 Email from Adams to Seattle This exhibit establishes the defendant’s
Police Department knowledge with respect to the purpose of the
PPP program.
141 BOA Statement 7.25.2020- Shows disbursement of the first loan. The
8.24.2020 disbursement of the first PPP loan funds is
necessary to show that Adams received the
money. This goes directly to his certification on
his second PPP application that he received and
spent the funds for appropriate purposes. The
evidence goes to his intent on the second PPP
application and demonstrates a lack of mistake
or accident in the use of the second disbursement
of funds.
143 BOA Statement 8.25.2020- Same as above.
9.23.2020
3
This exhibit was not admitted at the first trial.
6
Case 1:21-cr-00625-APM Document 200 Filed 03/25/26 Page 7 of 11
Exhibit 2 Description 404(b) Purpose
144 BOA Statement 9.24.2020- Shows Adams’ financial state in the months
10.23.2020 leading up to the second loan and provides
context and motive.
145 BOA Statement 10.24.2020- Same as above.
11.20.2020
146 BOA Statement 11.21.2020- Same as above.
12.23.2020
147 BOA Statement 12.23.2020- Same as above.
1.11.2021
157 Docusign 7.31.20 Shows completion of application for the first
loan. This demonstrates a knowledge of the PPP
process and goes to an absence of accident or
mistake in the second loan application.
160 Family Dollar Receipt October Shows improper use of loan funds. This goes
2020 directly to his certification on his second PPP
application that he received and spent the funds
for appropriate purposes. The evidence goes to
his intent on the second PPP application and
demonstrates a lack of mistake or accident in the
use of the second disbursement of funds.
161 Family Dollar Product Detail Same as above.
October 2020
168 Foot Action Receipt September Same as above.
2020
168.1 Foot Action Product Detail Same as above.
September 2020
169 Gap Old Navy Receipt Same as above.
September 2020
171 GOAT Invoice January 2021- Same as above.
Redacted
7
Case 1:21-cr-00625-APM Document 200 Filed 03/25/26 Page 8 of 11
Exhibit 2 Description 404(b) Purpose
171.1 GOAT Invoice January 2021- Same as above.
Redacted
173 MGM National Harbor All Same as above.
Ratings Detail 1.01.20 to
9.01.21
174 MGM National Harbor Cash Same as above.
Club Detail Transaction Report
179 PPE Casino Resorts Annual Same as above.
Activity 2020
181 Tiki Lee’s Dock Bar Receipt Same as above.
8.9.20
182 U Printing Invoice and Picture Same as above.
8.9.20
185 Walmart Receipts Redacted Represented to be expenditures of SuperKlean
and show a lack of proper use of funds
demonstrating a lack of mistake or accident in
certifying the second loan application.
186 Additional Walmart Records Same as above.
Redacted
188 Wynn Player Review- Roberto Shows motive to apply to second loan and
Adams misuse of loan funds.
189 Wynn Encore Player Report Shows motive to apply to second loan and
misuse of loan funds.
191 Wynn and Encore Gaming Same as above.
Activity 2020
195.1 Legal Zoom Records for Shows creation of SuperKlean in June 2020.
SuperKlean LLC
195.2 Legal Zoom Records for Same as above.
SuperKlean LLC
8
Case 1:21-cr-00625-APM Document 200 Filed 03/25/26 Page 9 of 11
Exhibit 2 Description 404(b) Purpose
198 Article Attached by Bunche with Provides context of the first loan and knowledge
the First Loan Application of the PPP process.
199 Text Messages Between Bunche Same as above.
and Adams 12.30.20- 8.9.21
200 Video of Texts between Bunch Same as above.
and Adams 7.31.20 to 8.9.21
200.1 Text Messages between G. Shows Adams’ knowledge and understanding of
Bunche and R. Adams (7.31.20) the loan process and his relationship with G.
Bunche.
200.2 Text Messages between G. Same as above.
Bunche and R. Adams (7.31.20)
200.3 Text Messages between G. Same as above.
Bunche and R. Adams (7.31.20)
200.4 Text Messages between G. Same as above.
Bunche and R. Adams (7.31.20)
200.5 Text Messages between G. Same as above.
Bunche and R. Adams (8.4.20)
200.6 Text Messages between G. Shows motive and engagement for the second
Bunche and R. Adams draw.
(12.30.20)
200.7 Text Messages between G. Same as above.
Bunche and R. Adams (1.21.21)
200.8 Text Messages between G. Same as above.
Bunche and R. Adams (1.25.21)
200.9 Text Messages between G. Same as above.
Bunche and R. Adams (1.28.21)
200.10 Text Messages between G. Shows Adams’ knowledge and understanding of
Bunche and R. Adams (3.15.21) the PPP program.
9
Case 1:21-cr-00625-APM Document 200 Filed 03/25/26 Page 10 of 11
Exhibit 2 Description 404(b) Purpose
200.11 Text Messages between G. Shows Adams’ knowledge and understanding of
Bunche and R. Adams (6.18.21) the PPP program and loan forgiveness.
200.12 Text Messages between G. Shows Adams’ knowledge and understanding of
Bunche and R. Adams (7.28.21) the PPP program and loan forgiveness.
200.13 Text Messages between G. Same as above.
Bunche and R. Adams (8.21.20)
201 Phone Analysis for Adams Shows duration of conversation with Bunche at
time of the second draw.
210 Email from SBA to Adams re Shows Adams’ engagement and financial
EIDL competence. It is indicative of intent and lack of
accident.
215 Email from Scratch to Adams re Completes the narrative of Adams’
Loan Forgiveness 3.5.21 understanding of loan forgiveness.
216 Email from Adams to Bunche re Shows Adams’ knowledge and understanding of
loan Forgiveness 7.28.21 the loan process and his relationship with G.
Bunche and provides context of the first loan
application.
218 Email from Scratch to Adams re Shows Adams’ knowledge and understanding of
Loan Forgiveness 8.21.20 the loan process and provides context of the first
loan application.
226 SAM.gov Entity Overview Provides context of when SuperKlean was
Details 1.18.21 created.
As the Government argued during the motions hearing, its intent in introducing the
proffered evidence is not to cast aspersions with respect to Adams’ conduct surrounding his
application for the first loan. Rather, the intent is to show Adams’ knowledge of the PPP loan
process. The government seeks to introduce the exhibits listed above to prove motive, opportunity,
intent, preparation, plan, knowledge, identity, absence of mistake, or lack of accident with respect
10
Case 1:21-cr-00625-APM Document 200 Filed 03/25/26 Page 11 of 11
to Adams’ second loan application. Moreover, an essential element at trial is Adams’ intent. The
proffered evidence is offered to demonstrate that in seeking a second PPP loan, Adams’ was not
mistaken about the application process, the purpose of the PPP money, or that the money was
intended for specific usages. The prior-acts are also being offered as evidence of motive and
knowledge. See United States v. Brown, 597 F.3d 399, 404 (D.C. Cir 2010) ([e]vidence of [a
defendant’s] intent, as demonstrated by extrinsic evidence of knowledge, motive, and the absence
of mistake or accident, was relevant to show his specific intent to defraud.”). In Brown, the Circuit
found that the evidence the government sought to introduce was both temporally and substantively
related to the charged conduct. Similarly, here Adams’ first loan application coupled with his use
of the funds from that loan are both temporally and substantively related to his conduct in the
second loan and show the defendant’s intent to fraudulently obtain funds in this second loan
application.
CONCLUSION
For the foregoing reasons, the Government respectfully requests permission to introduce
the above-described evidence as intrinsic evidence or other crimes evidence pursuant to Fed. R.
Evid. 404(b).
Respectfully Submitted,
Jeanine Ferris Pirro
United States Attorney
By: /s/ Caelainn Carney
Caelainn Carney (N.Y. Bar No. 5751672)
Sarah C. Santiago (GA Bar No. 724304)
Assistant United States Attorneys
United States Attorney’s Office
601 D Street, N.W.
Washington, D.C. 20530
Email: caelainn.carney@usdoj.gov
Telephone: 202-714-6433
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