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Complaint against Bank of America, Megan Scholz with Jury Demand — No. 1:21-cv-00748 (Dkt. 1)

Summary

A complaint with a demand for jury trial filed September 3, 2021 as Document 1 in Favorite Things, a DBA of Natasha Athens, v. Bank of America and Megan Scholz, Case 1:21-cv-00748-SM, in the United States District Court at Concord, NH. The complaint, signed by Athens as proprietor, alleges that Bank of America changed the terms of forgiveness on the plaintiff's PPP loan and cites 18 U.S. Code § 1344 along with claims of emotional distress, harassment and unjust enrichment. It quotes a May 12, 2020 bank email advancing a new loan amount of $18625, and alleges that Scholz, a bank VP, changed the forgiveness position 4 times and terminated a forgiveness application put through on July 30, 2021. The complaint seeks several awards of $1 Million dollars and $500K from the defendants.

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Cite this document

“Complaint against Bank of America, Megan Scholz with Jury Demand — No. 1:21-cv-00748 (Dkt. 1).” Original at archive.org. Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/complaint-against-bank-of-america-megan-scholz-with-jury-demand-no-1-2-bcf1bbebbb/, SHA-256 3a89ad885b2cb94dd561b5d66367d94a4a3f89f04a806ab2b64c617e3378c92c.

Full text

                  Case 1:21-cv-00748-SM Document 1 Filed 09/03/21 Page 1 of 17

     . USDC ~NH
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                                UNITED STATES DISTRICT COURT
                                          Concord, NH
         District of Merrimack NH                                Docket #


                                         Favorite Things
                                              a DBA
                                         Natasha Athens
                                                V.
                                      Bank of America et a
                                          Megan Scholz
                                           Defendants


         Demand for JuryTrial

         Jurisdiction is based on the diversity of Citizenship

         This complaint is based on Bank Fraud and a scam to rob small businesses
         by changing loan terms on the borrowers from the Federal CARES Act
         Forgiveness Program. Bank of America is changing the loan terms on
         THOUSANDS of their customers, and harssing them, bullying them, and
         resorting to even canceling loan forgiveness, which is in direct violation of
         federal law. Defendant Megan Scholz, senor VP bully, is lying to her
         customers and printing fraud in her emails, while tampering with loan
         forgiveness. Megan has changed the terms 4 times on the Plaintiff, and
         countless others. This fraud is so criminal, and meant solely to enrich BOA
         at the cost of their small business network of customers throughout 50
         states.

         It is inconceivable that serveral of the staff are single handedly wiping out
         small businesses and forcing them into bankruptcy, because they have no
         ability to repay the loans.

         The Plaintiffs loan worked out to $43 a day, over the course of the

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       Case 1:21-cv-00748-SM Document 1 Filed 09/03/21 Page 2 of 17




pandemic, and for that Bank of America stopped her forgiveness loan, since
the Plaintiff fought for full forgivenss and called out the bank, and
Defendant Megan Scholz, who is a pathological liar, and presents herself as
a giver of donations.

VP Megan Scholz is a buily, and wants sole control over her abuse to her
customers. Even though the SBA offers direct forgiveness, Defenant Megan
refused to enter in.


Brian Moyhihan is also complicit, and not responding to fixing the loans
that were to be forgiven. They are overbilling, and scamming the fund for
massive wealth.


COMPLAINT FOR LOAN FRAUD, PPP PROTECTION SCAM, 18 U.S. Code §
1344 - Bank fraud. Infliction of Emotional Distress during a Crisis,
Harassment, Bullying, Invasion of Privacy, Violations of the CARES act, the
SBA guidelines, and Federal law for the Approved loan funds Unjust
Enrichment Case # 122 N.H. 120(1982) PETER PETRIE-CLEMONS & a.
V. WALDO BUTTERFIELD. No. 80-480.

1.     Favorite Things, a sole propietor retail business located in Keene NH
located at 540 Main St, Keene NH 03431. It is a DBA, with Natasha Athens
as propietor. She is nearly broke and in serious debt from the 1.5 year long
pandemic, and the money she borrowed was set up for her, and businesses
like hers. While she had a strong and profitable beginning, she was only in
operation a short time, and then closed by the Governor.

2.     Bank of America atl50 N. College St., Charlotte, NC 28255 is violating
the rules of loans, and the intent of the CARES act set up by the SBA. CARE
Loans under the CARES Act and the PPP Flexibility Act, in 2020. Federal AID
was set aside to loan 2.5 weeks of payroll to aid businesses hit hard during
a nationwide crisis. The Defendant Megan on behalf of BOA is canceling
those loans out, while in process of forgiveness. This is criminal, and highly
illegal, and yes, a conspiracy against the very people the funds were meant
for.



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 3.     Bank of America is pulling off the biggest heist from their own small
 business banking customers that the world has ever seen, and they are
 getting away with it thus far. While 1/3 of the USA depends on small
 businesses, during COVID-19, many of them were wiped out. Funds set
 aside through the CARES act, and SBA, was distributed through multiple
 banks and attached to your business banking accounts. Different banks
 used similar procedures to put the loans through. These loans were
 approved in the budget by Congress and the Senate and approved. In
 order to obtain the loans, it was based on 2.5 weeks of payroll. This was
 during over 500 days of injury to businesses, and extended lockdowns.

Forbes has already called out BOA since what they did was issue the loans,
and then renag on the terms, which is not legal. BOA, the Defendant h as
engaged in a massive overbilling scam, into the tune of millions of dollars,
and then toppled that wealth, with targeting their small business customer
base.


https://www.forbes.eom/sites/kotlikoff/2020/07/13/another-horrific-
bank-of-america-horror-storv-that-hundreds-if-not-thousands-are-
^parently-experiencing/?sh=57fbe5704ee2


https.V/kotlikoff.net/contact/

When a mazagine based on high wealth is catching them in the act, one
would think they would have stopped what they were doing. Flowever, this
did not happen, as BOA in the times of social media, and CEO Brian
Moynhian being "CEO of the Year" appear to think that this crimes and
heist will not effect them.


In cases of unlawful enrichment, "during a worldwide crisis" the court
should rule that they must pay back every overbilled penny, and every loan
they conned their victims into accepting via "take it" or we will forgive 0
scam.


STATEMENT OF THE FACTS



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      Case 1:21-cv-00748-SM Document 1 Filed 09/03/21 Page 4 of 17




4.     The Defendant, Bank of America planned this theft and bank fraud at
the onset, and were demeaning their small business base. Under terms of
any loan, there is a set time when the loan comes due, and payments need
to be made. In the case of PPP loans, as long as the funds were used for the
intended purposes, they were 100% forgiven. There were no loopholes in
these loans, the SBA approved loans to small businesses, and they were to
be forgiven in full. Defendant Megan changed her own arguement 4 times,
from first was the Plaintiff was at fault and only 2/3 of her loan could be
forgiven. 2) Then it was anger directed at her for emailing her the law and
she changed it to "bank error" 3) She changed it to 0 forgiveness. 4)She
changed it to $1 forgiveness and then to appeal that. These are all IN
WRITING, despite the Plaintiff's HIGH earnings when she started and her
taxes. See exhibits further down of loan approval . The process to get
approved was torturous and so grueling but it was BASED ON EARNINGS
and PAYROLL. There was no other way to get the loan approved. Megan's
arguement is that of a 1st grader, and 0 math skills so how does that
person obtain a job at bank? Good question. Any person that has a law
degree and has to hire a lawyer for their actions = a liability and not
either a good employee, or a good lawyer.

5.     The Defendant BOA, harassed, stalled, and lied to customers, and
made money on every 1-800 call that their customers needed to make due
to their own bad policies. This was part of the scam. They used every tactic
known to man, to stall out and delay even approval of the loans. In the
case of the Plaintiff, while she used her initial tax data in a very new
business, she sought $12,500 for her 2.5 weeks of payroll based on her
known earnings that she had calculated. Upon many efforts to submit
those documents and being denied and BOA sought more records, they
ended up offering her $500. for her "loan". Not based on anything. The
bank had to even apologize for that insane offer.

6.    The Plaintiff rejected that loan, went to for accounting advice and
found out she earned more, and resubmitted the documents and had to
reach the then VP, Naushaba Zahid who received her application on
escalation and with her refiled documents, approved her loan, and wrote
this to her on May 12, 2020.

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       Case 1:21-cv-00748-SM Document 1 Filed 09/03/21 Page 5 of 17




5/12/2020 4:25 PM
Good afternoon Ms. Athens,

It was a pleasure to speak with you today and to discuss your escalation for
the PPP calculations.


I just wanted to let you know I have advanced your escalation to our SBA
team to work on getting you a new loan amount of $18625 based on your
2020 941 for 1st qtr and the 2019 Schedule C based on one month of
business.


Thank you for being a valued Bank of America client
Naushaba Zahid,
Vice President|Preferred and Small Business Banking
Bank of America Baltimore Area


7. The loan was then distributed from the SBA, and put into the Plaintiff's
business checking account. The funds were used exactly as distrubited, and
while the Plaintiff awaited instructions for forgiveness, they never came.
There were emails and phones calls throughout 2020, and other banks
were already forgiving loans, but not the Defendant, who put out the
second PPP loan application process, prior to the 1st forgiveness
application.


8. In February 2021, they offered 2nd PPP Loans, which the Plaintiff
qualified for. The Plaintiff was quite leery at this time, but she went through
the process of doing the 2nd PPP loan application, but she saw how much
they changed the process, further distressed out their own small business
base, and then made money from billing for the applications, but most
people, including the Plaintiff did not accept it. The Plaintiff was only
offered $1,000 for the 2nd PPP loan, that is double the original amount
despite her payroll being much higher, but she declined to fill out a revised
application and passed on the 2nd PPP based on what BOA,the Defendant
was doing to their customers.



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      Case 1:21-cv-00748-SM Document 1 Filed 09/03/21 Page 6 of 17




Everyone needed the funds, that is why they were offered. The Plaintiff
and others sustained massive rent and overhead bills due, despite being
closed. The Plaintiff paid over 50K in overhead to sustain a closed business
and not lose it. But the Defendant was not being good to their customers,
and instead just forcing everyone to have their paperwork not approved,
and resubmitted, only to realize they were still insulting and targeting their
own customers.


Had the Plaintiff finished the 2nd application, BOA,the Defendant had
planned to use the amended 2nd application against her, even though
everyone had options to choose different quarters for their payroll in order
to get the 2nd PPP loan.

The "secret" in this process was told to the Plaintiff on August 25, 2021 with
Stephany who revealed the despite the Defendant BOA denying forgiveness
on many of the 1st PPP loans, the "second loans" were not having that
problem. However 2nd loans were actually approved FOR THE EXACT
AMOUNTS OF THE FIRST PPP LOANS, BUT NOT HIGHER.

SO if those loans were distrubuted 2 times under CARES act, with the
same amounts of payroll, then the loans were to be forgiven across the
board as issued. Was it magic that the 2nd PPP loans matching the
original payroll on THOSE APPLICATIONS were "accurate" but on every
loan in dispute, for just about 1/2 of the loan amount being offered for
forgiveness only those loans had "errors? NO, all loans were to be
forgiven.


IF BOA had any evidence that the applicants and recepients did not
legally obtain the loans, or use them properly for business expenses, it
became a crime and their job would be to file criminal charges against the
borrowers. And only in those cases, where it is proved to be an act of
fraud that they obtained and misued the funds, could the loans not be
forgiven.


So what the Defendant did across the board was target many of their small
business owners, and for others, put through the 2nd loans for the same

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      Case 1:21-cv-00748-SM Document 1 Filed 09/03/21 Page 7 of 17




amounts as they were loaned. The ones they targeted, according to the
SBA were only being offered forgiveness for about 60% of the loaned
amounts.

9.    It was never necessary to take so many hours, emails and phone calls
to approve these loans, this was BOA, counting their wealth by overbilling.
Other banks had loans approved, submitted, and forgiven, while BOA
purposely timed out the option to get the loans forgiven.

10.    BOA did not even submit forgivness applications until May 2021, and
then they were not for the loaned amount, but only a portion. The Plaintiff
never was given written notice of her loan being fraudulent. She was not
criminally charged for her loan being mis-spent. The Defendant was
bombarded with their broke and struggling businesses and for everyone
that tried to obtain forgiverness for the loaned amounts, they were
harassed, bullied and lied about.

11.   BOA lied to their own staff, and told them to tell customers that they
were audited, and people were given too much money, therefore, they
cannot forgive the whole amount. This is FALSE. In fact, the surge of
thousands of phone calls to the SBA prompted them to investigate what
was happening, and in August 2021, they sent out an email to every single
loan recepient, and offered them direct forgiveness through their portal.

This portal was offered in August 2021, and according to the SBA, they are
processing forgiveness in full "very quickly" as it was meant to be.

https://directforgiveness.sba.gov/requests/borrower/login/7next-/

12.   BOA, the Defendant has refused to surrender their theft of funds,
and release their own customers and join in the forgiveness portal offered
by the SBA. This "hold" they want is to maintain the fraud and prevent
loans from 100% forgiveness. This is in direct violation of banking laws,
federal laws, the CARES act, and the SBA.




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       Case 1:21-cv-00748-SM Document 1 Filed 09/03/21 Page 8 of 17




STATEMENT OF THE CASE

 13.   The cruelty and criminality of the actions of Bank of America, the
Defendant, toppled with the vicious personal slander, defamation, and
falsely reporting a crime of Megan Scholz, is unconscionable.

14.   Brian Moynihan, the BOA CEO is also invovled in this crime, scam,
bank fraud, and overbilling of PPP Cares act funds. Unlawful enrichment
should be paid back to all parties, including the Plaintiff. 122 N.H. 120
(1982)
PETER PETRIE-CLEMONS & a. v. WALDO BUTTERFIELD. No. 80-480.

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From the fraud of the Defendant, the Plaintiff was not safely able to obtain
a 2nd PPP loan, despite those funds being approved for her and many
others, but they put enough obstacles in the way, while paying themselves
and prohibititng her right to that money, the subject of the funds in a
federal bill, the CARES act.


The Defendant sent emails and banking messages urging people to take the
2nd PPP loan, and the Plaintiff knew at this point in 2021, that she could not
rely on the bank. Many people were confused as to why the bank was

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      Case 1:21-cv-00748-SM Document 1 Filed 09/03/21 Page 9 of 17




tripping up the 2nd right to obtain loans, and the answer to that is theft of
the funds via the bank.

15.   The Plaintiff contacted the PPP Outreach and escalation team, and
they were indeed shook up enough from her emails to change her loa n
amount to the full loaned amount, despite Megan stating they would not,
and manipulating the SBA PPP loan statues.

This is Megan's 3rd version of her manipulations and cancelation of her
loan AFTER IT WAS IN PROCESS TO BE FORGIVEN.


"As noted above, the SBA does not require lenders to check borrowers
calculations, rather lenders are specifically empowered to rely on the
calculation of maximum loan amount by the borrower. Your assertion that
the Bank had a duty to correct Favorite Things' calculation or inform
Favorite Things of their improper calculation of their loan amount is
contrary to the facts and law.


 We understand you may be disappointed with the Bank's position, but the
Bank considers this matter resolved and will respond to no further
communications from you related to Favorite Things' maximum forgivable
loan amount. Thank you for your business."

Megan has been using those lines on many customers in order to force
them to accept less than they loaned amounts. She is bascially twisting the
crime of bank fraud onto businesses, while stating falsely that they are
committing fraud when their own taxes were what was submitted.

In this email, BOA staffer Megan is in fact WRONG. Loans are given in 100%
certain terms, they cannot be changed once the borrower has received the
funds and then owes them back. This action is a mob-like mentality and a
threat to banks globally. It's LENDER FRAUD, not lendee fraud.

16.    The Plaintiffs full forgiveness amount was manually entered on July
30, 2021 and on its way to the SBA. They had repeatedly WRITTEN emails
to the Plaintiff that they would submit a new application and then never

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      Case 1:21-cv-00748-SM Document 1 Filed 09/03/21 Page 10 of 17




did, but while her application for the $12,500 in forgiveness was in route to
the SBA, then changed to the $18,625 - email confirmation of this
Favorite Things on July 30, 2021
PPP loan funded on: May 14, 2020
PPP loan ending in: 7304
Bank of America has submitted a decision to the Small Business
Administration (SBA)that the full forgiveness amount you requested on
your Paycheck Protection Program (PPP)loan should be forgiven. The SBA
will make the final decision on your forgiveness application.

17. On August 9, 2021, Megan pulled and withdrew the application and
wrote an angry email to the Plaintiff, stating she had put forgiveness down
to 0. This time, Megan blamed it on a "bank eror" vs calling the Plaintiff a
fraud.


This is Version 3 of Megan's emails.

 The Bank has reviewed the documents submitted by Favorite Things and
determined there was an error in the Bank's prior calculation of maximum
forgivable loan amount. Upon closer review of the documents provided,
the wage information provided is conflicting and the correct maximum
forgivable loan amount is $0. Favorite Things will need to repay the entire
balance of the PPP loan received pursuant to the terms of the Promissory
Note executed by you on behalf of Favorite Things.

If a bank gives out the "wrong change" to a customer, that loss is on the
bank. If the "bank" miscalculated a loan amount based on taxes and
payroll, that is NOT on the borrower. Megan has some sort of issue with
her inability to know banking rules, lending rules, and basic math. She also
wrote conflicting emails, first blaming the Plaintiff, then blaming the
"bank".


This is unconsciouble and Defendant Megan Scholz does not have the
"overriding power" to nullify loan terms based on her triggered emotions.
This is beyond fraud, and one does have to question the sanity of anyone
that would pull off a "heist" with forgiven federal funds.

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      Case 1:21-cv-00748-SM Document 1 Filed 09/03/21 Page 11 of 17




The fact that any staff member would even consider this, be so drunk with
power and addicted to mistreating their own customers, is something that
has to be investigated.


18. On August 23, 2021, in more massive overbilling and derangement
emails from Megan Scholz, she then stated she would continue to "time
out" the forgiveness options and in 2 weeks, put through a forgiveness
application for $1.00.

This is version 4


Per your request, a new PPP forgiveness application invitation will be
provided to you. As communicated previously, your PPP loan does not
appear eligible for forgiveness. The PPP forgiveness application invitation
you receive will reflect a maximum forgivable loan amount of $1. Once this
application is processed, you will have an automatic right to an appeal as
outlined below.

19.   There has to be discovery on how much BOA, the Defendant has
billed Cares Act, and PPP for their hours, and specifically Megan Scholz.
When the Plaintiff spoke with the SBA, they stated there were other
complaints about Megan, the Defendant.

On August 25, 2021, client outreach filed an ethics complaint on Megan
Scholz, which is what the SBA stated had to happen first. Complaint #
045163S and Case #210825SC007228 was about the 7th complaint filed on
this case, but the first complaint on ethics.

Prior to this, there were several escalations, are 5000W00001J82QAE ,
June 11#210611SC004254 and July 26 2021 # 5006T00001BXEZQAO

It is August 30, 2021 and no one has called back on the escalation and call
for bank fraud. Why? They know excactly what they are doing and they
cannot even respond.



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As everyone can see from the 5000 series, to the 5006 series in July, this is
a nationwide scam, and all of the victims of this plot to pull a multi-million
dollar bankfraud scam has people fighting it.

The Defendant has been billing PPP Cares Act, for THOUSANDS of hours of
time and calls. And the escalation team is huge, however, they are being
lied to by BOA staff, and the point we are now, they cannot handle the
loans being approved.

All of the context was done on l ine, but in the process to scare BOA
customers, in June, they MAILED Out a letter, telling people to accept the
fraudulent forgivess terms or their loans would come due in October 2021.
This was again, the intention of BOA, the Defendant to steal from their own
customers and obtain millions in unforgiven loans and interest.

20. Defendant Megan Scholz told the Plaintiff that she would have to
"appeal" the decision of her unforgiven loan, since Megan went in and
canceled the application. She was also intimidated by the Plaintiff's
abilities, and knowledge and she expected that the Plaintiff, like so many,
would not question her. We have to question the Defendant Megan, since
her actions are not things that sane, competent people do to their
customers.

STATEMENT OF THE FACTS

21.    The Defendant Bank of America has sought unlawful enrichment
during a crises, while lying to their first level and second level staff. They
are telling them lies so they are not even aware of the scam being pulled
off. At the phone answering first tier level, they do not have access to
entire accounts or notes, and are simply responding to calls.

22.    NO one needed to make hundreds of calls to BOA, the Defendant
regarding loan approval, loan forgiveness, and 2nd application. The
Defendant made it impossible for businesses to obtain their rights to both
loans and forgiveness.



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23.   What has to be discovered is how many banks were issuing the loans
by the SBA, and how many joined the portal for direct forgiveness?
According to phone calls to the SBA, they were having problems with Bank
of America the most, and in the case of the Plaintiff, it was unheard of to
"cancel a forgiveness application in process" and that has to be dealt with,
and the person that cancled it, questioned for motives. It cannot legally be
done.

24.    Defendant Megan is dillusional and cancel a forgiveness application,
and that leads to her criminality, and other factors about her. Who would
ever give that much power to a bank staff member?

25.   The BOA staff is determined to steal from their customers to this
massive degree, and then also receive 1% commission on the interest of the
unforgiven funds, (exhibits) BOA payment on loans https://michaeb
beniamin.medium.com/the-bank-of-america-ppp-scam-f976bfa46ac5

26. On July 21, 2021, Michael from BOA of Ohio had a more than 25 minute
cal! with me. He continued to put me on hold multiple times, while he
"researched" the Plaintiffs escalation. He stated that he was forced to read
a statement, and in that statement, he cited the "middle layer" to the
process to obtain a loan, the initital figure of the $5,000 a week and he
recited that based on those figures, which were later amended not once,
but twice, to higher and total amounts, that the loan was based on, they
were still ignoring the final part of the application process that led to the
approval and the loan being signed.

Michael was a 66 year old man, and very kind, a good employee, and he
fomulated a new escalation, based on our conversation, and the letter with
my loan amount from the Vice President of on line banking. She was also
very competent, and trying to help, and was not in that department for the
2nd wave of loans. But her job was to help in the crisis and she did that,
and there was no fraud on anyone's part. The fraud happened by BOA, to
purposely use anything during the process that they had in the submitted
documents to use and "blackmail" the business owners, the PPP applicants
into not forgiving what they were loaned. This involved people nationwide.

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and for the escalation numbers to have jumped from 5000, to 5006, we are
talking about millions, if not billions of dollars being scammed.


27. On July 26, 2021,(Exhibit) after no one contacting the Plaintiff since
the June 11, escalation, she received a letter from the Defendant Bank of
America, telling her to "accept the forgiveness amount" as the first loan
repayment is due on October 14, 2021. This is how they are going to scam
the majority of people into their bank fraud plot, and force them to accept
the 2/3 amount or less, whatever they sent in their forgiveness application.

28. On August 25, 2021, that phone call revealed that people are waiting
months for escalation teams to call them back and they are not doing it.
They are timing out the forgiveness option, while customers are scared,
unable to pay back loans and some are being forced into bankruptcy. This
is again, unconscionable. The Defenants both BOA and Megan have to be
sociopaths to be targeting the businesses that have survived at all during
this pandemic.

ARGUEMENT


29. The Federal Goverment declared a USA state of Emergency, and the 50
states had different results from that declaration. Small businesses were
effected, and many were wiped out. In each of the emergency plans put
into place, PPP loan forgiveness, Coronavirus Aid, Economic Security CARES
act, the PPP Flexibility Act, the Economic Aid Act, and the SBA, these
combined agencies were given billions to distribute. The Plaintiff's portion
of this was a one time small amount 2.5 weeks of payroll in a 425 day or
more crisis. That $43 a day (if we divide that loaned amount by the entire
crisis) would not pay a light bill. For either home or the business of the
Plaintiff.


What BOA, the Defendant is doing, on a 50 state scale is taking that $43 a
day, and putting 1/3 of it back into their pockets x al l of the businsses that
took a loan. On top of that, they are making 1% interest on that money per
person. On top of that, they are being paid by the hour.



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 People and businesses cannot come out of this loss - ever. The bravest of
businesses have put everything on the line, taken more federal or state
loans, and WANT to be giving the services they provide in business to the
country. The sad thing about monopolies, is that personal service is gone.
All of the mom and pop businesses, the backbone of this country are
fighters and most of the love what they do.

The hardships of 2020, 2021, will be felt for a century, but they are
amplified by the sick greed, actions and crimes of the Defendants.


Megan has assaulted the character, standing and integrity of the Plaintiff's
entire life's work which was to support herself through to retirement. This
was at the cost of many things in her life, she could not obtain many things
as a sole propeitor that others had with steady paychecks and secure jobs,
but that was still her choice.


The way that the Defendant has violated the trust, the rules of bank loans
and every federal fund that was set up for aiding in this crisis, is something
that everyone involved should do life in prison. The courts cannot cover for
this or enable this.


In the past there was the HSBC bank scam, which was fought out in court
for years, and they lose, paying a huge fine. That fine did not help the
recovery of the victims. Here, BOA the Defendant is ROBBING the entire
country, and spreading out their victims through 50 states - while stealing
the very money intended to save them.

In a world gone mad, the predators have lost touch with reality. Anyone
that could steal from the neighborhood while everyone is suffering cannot
be mentally stable. This type of greed is a sickness.

JP Morgan, who stole, just had to pay back millions. While of different
content than PPP loan fraud, there was the same criminal robbery, lies and
deciet to innocent people.

https://www.iustice.gov/opa/pr/ipmorgan-chase-co-agrees-pav-92Q

                                     15
      Case 1:21-cv-00748-SM Document 1 Filed 09/03/21 Page 16 of 17




 miHion-connection-schemes-defraud-precious-metais-and-us

 CONCLUSION


 Defendant Megan Scholz is bringing down Bank of America, in her own
 cloak of fraud on to small businesses. She cannot cancel loans that were
 used as intended, and the Plaintiff broke down her loan into exactly the
allowances that were allowed, and she paid her $3K a month rent with that
money to keep a business going that was closed for more than 110 days by
the Governor. She lost the entire business, and donated more than 12
truckloads of her investment to the Keene Salvation Army. It was
devastating and she was unable to save it because of the "pandemic”.

The loan allowed her to pay for business costs, and she gets to have them
forgiven. The fact that Megan Scolz is "wearing the pants" at Bank of
Arr,erica to terminate the loan forgiveness process "because she is mad" at
the customers she cannot blackmail into accepting partial forgiveness is a
move that needs to land her in jai l. And anyone that enables her.

The Plaintiff is entitled to damages, including the loan she was not able to
secure due to BOA’s consistent fraud to deter borrowers from receiving
federal funds.


If the Plaintiff HAD sought her 2nd loan, using different dates to calculate
her payroll, as she had to in the first loan, the Defendant would have
 accused her" again of fraud to receive her own proper lawful amount.

She was unable to trust her bank, a necessary and required element of
banking.


Megan, the Defendant cannot insult, and verbally assault businesses, and
demean their brands and integetrity in order to secure her own "steal" and
"theft" of PPP funds and forgiveness.

She owes the Plaintiff $1 Million dollars forthe destruction of the business
"Favorite Things.

                                     16
      Case 1:21-cv-00748-SM Document 1 Filed 09/03/21 Page 17 of 17




She owes the Plaintiff $1 Million dollars for harassment discrmination,
verbal abuse, demeaning her loan amount to "0".

Defendant Bank of America owes the Plaintiff $1 Million dollars for
harassment, and failing to respond to her needs as a bank customer.

Defendant Bank of America owes the Plaintiff $1 Million dollars for 1.5
years of abuse, time, emails messages, and failure to respond to her more
than 40 phone calls, needs, and resolution of all of her bank issues over
federal funds that were to be disbursed 2 times.

Defendant Megan Scholz owes the Plaintiff $500K for terminating an
forgiveness application in process that was put through on July 30, 2021.
This act alone is so vicious and illegal that she should be fired and arrested
for this act of fraud.


Defendant Bank of America owes the Plaintiff $1 Million dollars to the loss
of her business, the right that she had to access federal funds from the
CARES act, and for not handling the problem employee they have, one that
approved the entire loan at the onset, and their "vice President" that has
abused all banking policies, codes of ethics, rules, and stopped a
forgiveness application that was manually changed to the total loaned, and
on its way to forgiveness.



Is/
Signed,
Natasha Athens
Prcpietor Favorite Things

File August 30, 2021




                                      17


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