Amended Information — United States v. Adewale Matthew Abel (Northern District of Oklahoma)

Summary

An Amended Information filed September 8, 2020 as Document 5 in United States of America versus Adewale Matthew Abel, Case 4:20-cr-00148-CVE, in the United States District Court for the Northern District of Oklahoma. The United States Attorney charges a false statement to a financial institution under 18 U.S.C. § 1014. It states that from on or about May 3, 2020 to on or about May 11, 2020, Abel sought a PPP loan of approximately $300,000 from Stride Bank for Pinnacle Industry LLC, falsely representing an average monthly payroll of $120,000 and 20 employees and submitting a false payroll summary report. The forfeiture allegation seeks a money judgment of at least $300,000.00 under 18 U.S.C. § 982(a)(2).

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Case 4:20-cr-00148-CVE Document 5 Filed in USDC ND/OK on 09/08/20 Page 1of4

Lo. FILED

IN THE UNITED STATES DISTRICT COURT SEP 0 8 2020
FOR THE NORTHERN DISTRICT OF OKLAHOMA Mark GC. McCartt, Clerk

U.S. DISTRICT GOURT
Case No. D0-ce-l4e- JET ry

UNITED STATES OF AMERICA,

Plaintiff, AMENDED INFORMATION
[18 U.S.C. § 1014 — False Statement to

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Vv. ) a Financial Institution;
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Forfeiture Allegation: 18 U.S.C. §
982(a)(2) — Fraud and False Statement

ADEWALE MATTHEW ABEL,
Defendant.

THE UNITED STATES ATTORNEY CHARGES:

Li From on or about May 3, 2020, to on or about May 11, 2020, in the Northern
District of Oklahoma, the defendant, ADEWALE MATTHEW ABEL, made false
statements and reports for the purpose of influencing in any way the action of a financial
institution, Stride Bank, upon an application and loan, in the following manner:

Ben For the purpose of securing a loan in the approximate amount of $300,000
for a company, Pinnacle Industry LLC (“Pinnacle”), that ABEL claimed to own and
operate, pursuant to the Payment Protection Program (“PPP”) administered by the United
States Small Business Administration, ABEL knowingly and intentionally:

a. falsely represented in a PPP “Borrower Application Form” that he
submitted to Stride Bank that Pinnacle:

a. Had an average monthly payroll of $120,000;

b. Had 20 employees;

a Was in operation on February 15, 2020, and had
employees for whom it paid salaries and payroll taxes; and
Case 4:20-cr-00148-CVE Document 5 Filed in USDC ND/OK on 09/08/20 + Page 2 of 4

d. Would use the loan funds to retain workers and maintain
payroll or make mortgage interest payments, lease payments,
and utility payments, as specified under the Paycheck
Protection Program Rule;
b. falsely certified in the PPP “Borrower Application Form” that he
submitted to Stride Bank that the information provided in the application and
supporting documents was true and accurate in all material respects; and
c. submitted to Stride Bank, as a supporting document for the PPP
“Borrower Application Form,” a false “Payroll Summary Report for Pinnacle
Industry LLC / July 2019 to March 2020.”
3. The accounts of Stride Bank were then insured by the Federal Deposit

Insurance Corporation.

All in violation of Title 18, United States Code, Section 1014.
Case 4:20-cr-00148-CVE Document 5 Filed in USDC ND/OK on 09/08/20 Page 3 of 4

FORFEITURE ALLEGATION
[18 U.S.C. § 982(a)(2)]

The allegations contained in this Amended Information are hereby realleged and
incorporated by reference for the purpose of alleging forfeitures pursuant to Title 18,
United States Code, Section 982(a)(2).

Upon conviction of the offense alleged in this Amended Information, as a part of
his sentence, the defendant, ADEWALE MATTHEW ABEL, shall forfeit to the United
States, any property constituting, or derived from, or traceable to, the proceeds obtained,
directly or indirectly, as a result of such violation. The property to be forfeited includes,
but is not limited to:

MONEY JUDGMENT

A money judgment in an amount of at least $300,000.00, representing proceeds
obtained by the Defendant as a result of the offenses;

Pursuant to Title 21, United States Code, Section 853(p), as incorporated by Title
18, United States Code, Sections 982(b)(1) and 1028(g), and Title 28, United States Code,
Section 2461(c), the defendant shall forfeit substitute property, up to the value of the
property described above if, by any act or omission of the defendant, the property described
above, or any portion thereof, cannot be located upon the exercise of due diligence; has
been transferred or sold to, or deposited with, a third party; has been placed beyond the
jurisdiction of the court; has been substantially diminished in value; or has been

commingled with other property which cannot be divided without difficulty.
Case 4:20-cr-00148-CVE Document 5 Filed in USDC ND/OK on 09/08/20 Page 4 of 4

All pursuant to Title 18, United States Code, Section 982(a)(2).

Respectfully submitted,

R. TRENT SHORES
UNITED STATES ATTORNEY

Kristin F. Harrington, OBA #21185
Assistant United States Attorney
110 West 7" Street, Suite 300
Tulsa, Oklahoma 74119
Kristin.Harrington@usdoj.gov
(918) 382-2700


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