Complaint for Forfeiture — United States v. $10,000.00 in United States Currency (District of Colorado)

Summary

A verified forfeiture complaint in rem filed August 10, 2026, by the United States against $10,000.00 in United States currency seized from a J.P. Morgan Chase account, Case No. 1:26-cv-03624-PAB-NRN, in the U.S. District Court for the District of Colorado. It states that the funds were deposited on or about June 24, 2020, that JPMC confirmed them as EIDG funds, and that the United States Postal Inspection Service seized them on March 10, 2026. It describes a $20,832 PPP loan executed with Cecilia Bryant and a claim contesting the forfeiture received May 11, 2026. It seeks forfeiture under 18 U.S.C. §§ 981(a)(1)(C) and 984 for violations of 18 U.S.C. § 641 and 18 U.S.C. § 1343. Special Agent Gabriel Cazares of the United States Secret Service verifies the facts; Kurt J. Bohn signs for the government.

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Case No. 1:26-cv-03624-PAB-NRN Document 1 filed 08/10/26 USDC Colorado pg
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IN THE UNITED STATES DISTRICT COURT FOR
THE DISTRICT OF COLORADO

Civil Action No.

UNITED STATES OF AMERICA,

Plaintiff,

1. $10,000.00 IN UNITED STATES CURRENCY SEIZED FROM J.P. MORGAN
CHASE BANK ACCOUNT #359920250,

Defendant.

VERIFIED COMPLAINT FOR FORFEITURE IN REM

The United States of America, by and through United States Attorney Peter

McNeilly and Assistant United States Attorney Kurt J. Bohn, pursuant to Supplemental

Rules for Admiralty or Maritime Claims and Asset Forfeiture Actions G(2), states:

JURISDICTION AND VENUE

1. The United States of America (the United States) has commenced this

action pursuant to the civil forfeiture provisions of 18 U.S.C. §§ 981(a)(1)(C) and 984,

seeking forfeiture of defendant property based on violations of 18 U.S.C. § 641 (theft of

public funds), and 18 U.S.C. § 1343 (wire fraud). This Court has jurisdiction under 28

U.S.C. §§ 1345 and 1355.

2. Venue is proper under 28 U.S.C. § 1395, as some of the acts described

herein occurred in the District of Colorado.

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DEFENDANT PROPERTY

3. Defendant property is more fully described as: $10,000.00 in United

States currency seized from J.P. Morgan Chase (JPMC) account #359920250

(“defendant $10,000.00”), seized on March 10, 2026. The account was in the name of

“Cecilia D Bryant.” Defendant $10,000.00 is currently in the custody of the United

States Postal Inspection Service.

FACTUAL BASIS FOR FORFEITURE

4. Except as otherwise noted, all the following facts and information have

been discovered through my own investigation and the observations and investigations

of fellow law enforcement officers as reported to me.

BACKGROUND INFORMATION

5. On March 27, 2020, the President of the United States signed into law the

Coronavirus Aid, Relief, and Economic Security (CARES) Act, which provided

emergency assistance, administered by the Small Business Association (SBA), to small

business owners suffering adverse economic effects caused by the Coronavirus

(COVID-19) pandemic. The CARES Act established several new temporary programs

and expanded existing programs, including programs created or administered by the

SBA. Two sources of funding for small businesses were the Paycheck Protection

Program (PPP) and the Economic Injury Disaster Loan (EIDL) program. In addition, the

CARES act authorized the SBA to issue advances, known as Economic Injury Disaster

Grants (EIDG), of up to $10,000 to small businesses. The amount of the EIDG was

determined by the number of employees listed on the EIDL application, and the EIDGs

did not need to be repaid.

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6. In order to obtain an EIDL and/or EIDG, a qualifying business was

required to submit an application to the SBA and provide information about its

operations, including the business’s gross business revenues and cost of goods sold in

the twelve months prior to January 31, 2020. The amount of the loan, if approved, was

determined based on the information provided concerning the gross revenue and cost

of goods sold.

7. JPMC began to identify PPP funds deposited into numerous bank

accounts after April 1, 2020, that it suspected constituted proceeds of PPP fraud. After

identifying the accounts, JPMC froze the account funds and maintained them as likely

proceeds of PPP fraud activity.

8. On March 5, 2021, SBA began allowing sole proprietors and independent

contractors to calculate their PPP loan using their gross income amount instead of the

net profit on their tax form Schedule C. The maximum loan amount for a sole proprietor

with no employees was $20,833 (the PPP program has a cap of $100,000 on the gross

income or net profit amount: $100,000 / 12 then multiplied by 2.5 = $20,833).

Ms. Bryant’s PPP SBA Loan

9. On April 17, 2021, Ms. Bryant completed and signed a W-9 Form

(Request for Taxpayer Identification Number and Certification) that was required by

SBA to be considered for a loan. It was found that Ms. Bryant had filed two different

Schedule C Forms in 2019. On the first Schedule C, Ms. Bryant states that she has an

“Exam Preparation & Tutoring” business with Gross Income of $99,996, Total Expenses

of $99,996, and with a Net Profit of $99,996. On the second Schedule C, Ms. Bryant

states that she has a “Caterers” business with Gross Income of $99,996, Total

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Expenses of $99,996, and with a Net Profit of $99,996, the same exact figures used on

the first Schedule C.

10. On April 17, 2021, Capital Plus Financial, LLC executed a PPP SBA Loan

with an individual by the name of Cecilia Bryant for $20,832.

Defendant $10,000.00 Seized from J.P. Morgan Chase Account #0250

11. On March 10, 2026, defendant $10,000.00 was seized from JPMC

account #0250 by the United States Postal Inspection Service (USPIS) pursuant to a

federal seizure warrant.

12. On May 11, 2026, the USPIS received an administrative claim from Cecilia

A. Bryant, contesting the administrative forfeiture of the defendant funds. In email

correspondence with Ms. Bryant, she states that there is a “significant misunderstanding

regarding the origin of these funds.” Ms. Bryant goes on to say that, “The $10,000

deposit was not related to an SBA loan or any SBA funding,” and “I am very confused

as to why the SBA has been referenced throughout this matter, as this situation has

never involved an SBA loan, a sole proprietorship, or any business-related funding.”

13. Ms. Bryant provided copies of payments to her from “Our Florida” for

“Tidal Basin Government Consulting LLC” and “IH4 Property Florida LP,” that were

dated May 7, 2022, matching the balance but for the wrong year and there is no SBA

documentation.

14. Deposit of defendant $10,000.00 was received by JPMC account #0250

on or about June 24, 2020. JPMC confirms that defendant $10,000.00 was EIDG funds.

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15. Between on or about April 1, 2020 and May 4, 2022, JPMC identified and

froze SBA funds deposited into numerous accounts, defendant $10,000.00 was one of

those accounts, as it was suspected to constitute proceeds of fraud.

CONCLUSION

In summary, there is reasonable cause to believe that defendant $10,000.00

constitutes or is derived from proceeds traceable to violations of 18 U.S.C. § 641 (theft

of public funds), and 18 U.S.C. § 1343 (wire fraud). Therefore, defendant $10,000.00 is

subject to forfeiture pursuant to 18 U.S.C. §§ 981(a)(1)(C) and 984.

VERIFICATION OF GABRIEL CAZARES, SPECIAL AGENT,
UNITED STATES SECRET SERVICE

I, Special Agent Gabriel Cazares, hereby state and aver under the pains and

perjury that I have read the foregoing Factual Basis for Forfeiture and that the facts and

information contained therein are true.

s/ Gabriel Cazares___
Gabriel Cazares
Special Agent
United States Secret Service

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FIRST CLAIM FOR RELIEF

1. The Plaintiff repeats and incorporates by reference the paragraphs above.

2. By the foregoing and other acts, $10,000.00 seized from J.P. Morgan

Chase account number 359920250 constitutes or is derived from proceeds traceable to

violations of 18 U.S.C. § 641 (theft of public funds). Therefore, defendant $10,000.00 is

forfeitable to the United States pursuant to 18 U.S.C. §§ 981(a)(1)(C) and 984.

SECOND CLAIM FOR RELIEF

3. The Plaintiff repeats and incorporates by reference the paragraphs above.

4. By the foregoing and other acts, $10,000.00 seized from J.P. Morgan

Chase account number 359920250 constitutes or is derived from proceeds traceable to

violations of 18 U.S.C. § 1343 (wire fraud). Therefore, defendant $10,000.00 is

forfeitable to the United States pursuant to 18 U.S.C. §§ 981(a)(1)(C) and 984.

WHEREFORE, the United States prays for entry of a final order of forfeiture for

the defendant property in favor of the United States, that the United States be

authorized to dispose of the defendant property in accordance with law, and that the

Court enter a finding of probable cause for the seizure of the defendant property and

issue a Certificate of Reasonable Cause pursuant to 28 U.S.C. § 2465.

DATED this 10th day of August 2026.

///

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Case No. 1:26-cv-03624-PAB-NRN Document 1 filed 08/10/26 USDC Colorado pg
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Respectfully submitted,

PETER MCNEILLY
United States Attorney

By: s/ Kurt J. Bohn_ __
Kurt J. Bohn
Assistant United States Attorney
United States Attorney’s Office
1801 California Street, Suite 1600
Denver, Colorado 80202
Telephone: 303-454-0100
Fax: 303-454-0405
Email: tonya.andrews@usdoj.gov

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