Information — United States v. Bernard Turk

Record facts

U.S. District Court, Central District of California · No. 8:22-cr-00061-JLS · Doc. 1 · 2022-05-09 · Docket on CourtListener

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UNITED STATES DISTRICT COURT 
FOR THE CENTRAL DISTRICT OF CALIFORNIA 
SOUTHERN DIVISION 
UNITED STATES OF AMERICA, 
Plaintiff, 
v. 
BERNARD TURK, 
Defendant. 
 
No. 
I N F O R M A T I O N  
[18 U.S.C. § 1343: Wire Fraud; 
18 U.S.C. § 2(a): Aiding and 
Abetting] 
The United States Attorney charges: 
[18 U.S.C. §§ 1343, 2(a)] 
A.
INTRODUCTORY ALLEGATIONS
At times relevant to this Information:
1.
Defendant BERNARD TURK was a Certified Public
Accountant running a tax preparation business in Tarzana, 
California. 
2.
Co-Schemer Mustafa Qadiri was a long-time tax client
of defendant TURK.  Co-Schemer Qadiri operated Agency 126, a 
purported advertising company located in Irvine, California. 
8:22-cr-00061-JVS
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5/9/2022
DTA

 
 
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The Paycheck Protection Program 
3.   The Coronavirus Aid, Relief, and Economic Security 
(“CARES”) Act was a federal law enacted in or about March 2020 
that was designed to provide emergency financial assistance to 
Americans suffering economic harm as a result of the COVID-19 
pandemic.  One form of assistance provided by the CARES Act was 
the authorization of United States taxpayer funds in forgivable 
loans to small businesses for job retention and certain other 
expenses, through a program referred to as the Paycheck 
Protection Program (“PPP”).  PPP loan proceeds were required to 
be used by the business to pay certain permissible expenses: 
payroll costs, interest on mortgages, rent, and utilities. 
4. 
In order to obtain a PPP loan, a qualifying business 
was required to submit documentation showing its payroll 
expenses, including federal tax filings. 
5. 
A small business’s PPP loan application would be 
received and processed by a participating lender approved by the 
Small Business Administration (“SBA”).  If a PPP loan 
application was approved, the participating lender would fund 
the PPP loan using its own monies, which were guaranteed by the 
SBA. 
SBA-Approved Lender 
6. 
“Bank A” was a financial institution and an SBA-
approved participating lender of PPP loans based in Marion, 
Illinois, whose deposits were insured by the Federal Deposit 
Insurance Corporation. 
 
 
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B.   THE SCHEME TO DEFRAUD 
7. 
Beginning in early February 2021 and continuing until 
at least on or about February 25, 2021, in Orange and Los 
Angeles Counties, within the Central District of California, and 
elsewhere, defendant TURK, aiding and abetting co-schemer 
Qadiri, knowingly and with the intent to defraud, devised, 
participated in, and executed a scheme to obtain money, funds, 
credits, assets, and other property owned by and in the custody 
and control of Bank A by means of material false and fraudulent 
pretenses, representations, and promises, and the concealment of 
material facts. 
8. 
The fraudulent scheme operated, in substance, as 
follows: 
a. 
On or about February 19, 2021, co-schemer Qadiri  
submitted a false and fraudulent application to Bank A for a PPP 
loan on behalf of Agency 126. 
b. 
To support the fraudulent PPP loan application, 
defendant TURK prepared a false 2019 Form 1120 U.S. Corporation 
Income Tax Return for Agency 126, claiming that Agency 126 paid 
$5,383,401 in wages during the 2019 tax year.  Defendant TURK 
provided the false 2019 tax return to co-schemer Qadiri to 
submit to Bank A in order to substantiate the amount of the 
fraudulent PPP loan.  To hide defendant TURK’s involvement, 
defendant TURK marked the false tax return “self-prepared.”  
 
 
c. 
Defendant TURK and co-schemer Qadiri knew that 
Agency 126 had no employees, paid no wages, and never filed tax 
returns with the Internal Revenue Service. 
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d. 
Co-schemer Qadiri electronically submitted, and 
caused to be submitted, the false 2019 Form 1120 U.S. 
Corporation Income Tax Return prepared by defendant TURK to the 
SBA and Bank A in support of Agency 126’s fraudulent PPP loan 
application.  On the false 2019 tax return submitted to Bank A, 
co-schemer Qadiri removed the “self-prepared” designation and 
replaced it with defendant TURK as the preparer. 
e. 
In reliance, in part, on the false 2019 Form 1120 
U.S. Corporation Income Tax Return, Bank A and the SBA approved 
and funded Agency 126’s PPP loan, and thereafter transferred 
approximately $1.2 million in loan proceeds by interstate wire 
into a bank account that co-schemer Qadiri controlled. 
f. 
For his role in the scheme, defendant TURK was to 
receive a small percentage of the loan proceeds when Bank A 
forgave the loan.  
C.   THE USE OF AN INTERSTATE WIRE 
 
9. 
On or about the February 25, 2021, in Orange County, 
within the Central District of California, and elsewhere, for 
the purpose of executing the above-described scheme to defraud, 
defendant TURK caused the transmission of $1,212,312 in PPP loan 
proceeds from Bank A, sent by means of an interstate wire, into  
/ / / 
/ / / 
/ / / 
 
 
 
 
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Agency 126’s Bank of America account in Newport Beach, 
California. 
TRACY L. WILKISON 
United States Attorney 
 
 
 
 
SCOTT M. GARRINGER 
Assistant United States Attorney 
Chief, Criminal Division 
 
BENJAMIN R. BARRON 
Assistant United States Attorney 
Chief, Santa Ana Branch Office 
 
JENNIFER L. WAIER 
Assistant United States Attorney 
Deputy Chief, Santa Ana Branch 
Office 
 
Case 8:22-cr-00061-JLS     Document 1     Filed 05/09/22     Page 5 of 5   Page ID #:5

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