Criminal Complaint — United States v. Kipterrez James (No. 1:24-cr-00039, S.D. Ohio)
Summary
A Criminal Complaint in United States v. Kipterrez James (a/k/a Kipp James, a/k/a Kip James), Case No. 1:24-mj-284, in the U.S. District Court for the Southern District of Ohio, sworn before Magistrate Judge Karen L. Litkovitz and filed 04/18/24 as Doc #: 1 in Case 1:24-cr-00039-MRB. It charges false statements under 18 U.S.C. 1001 on or about 4/6/2021 and 8/23/2021. The supporting affidavit of a Homeland Security Investigations special agent alleges that the defendant applied for a PPP loan claiming a taxi and ridesharing business with $99,489 in 2019 gross income, submitted a bank statement the bank had no record of, and received a $20,725 loan deposited April 17, 2021. It alleges the funds went to personal expenditures and that a forgiveness application falsely claimed the $20,725 was spent on payroll; the loan was forgiven.
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“Criminal Complaint — United States v. Kipterrez James (No. 1:24-cr-00039, S.D. Ohio).”
Original at archive.org. Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/complaint-no-1-24-cr-00039-dkt-1-s-d-ohio-b4d4fe4ae8/
, SHA-256 1536fb7821ef2778cc09168ed05c71ae1c9e2cd4cc248737d4e1079e6d1900d5.Full text
Case: 1:24-cr-00039-MRB Doc #: 1 Filed: 04/18/24 Page: 1 of 6 PAGEID #: 1
AO 91 (Rev. 11/11) Criminal Complaint
UNITED STATES DISTRICT COURT
for the
SouthernDistrict
__________ Districtof
of Ohio
__________
United States of America )
v. )
KIPTERREZ JAMES
) Case No. 1:24-mj-284
(a/k/a Kipp James, a/k/a Kip James) )
)
)
)
Defendant(s)
CRIMINAL COMPLAINT
I, the complainant in this case, state that the following is true to the best of my knowledge and belief.
On or about the date(s) of 4/6/2021 & 8/23/2021 in the county of Hamilton in the
Southern District of Ohio , the defendant(s) violated:
Code Section Offense Description
18 U.S.C. 1001 False Statements
This criminal complaint is based on these facts:
See attached affidavit
✔ Continued on the attached sheet.
u
Complainant’s signature
Special Agent Jason Greer
Printed name and title
Sworn to before me and signed in my presence.
via FaceTime video
Date: Apr 18, 2024 ~ ~~L~· , · · , ~
Judge’s signature
Karen L. Litkovitz
City and state: Cincinnati, Ohio UnitedKaren
Hon. StatesL. Litkovitz,
Magistrate U.S. Magistrate Judge
Judge
Printed name and title
Case: 1:24-cr-00039-MRB Doc #: 1 Filed: 04/18/24 Page: 2 of 6 PAGEID #: 2
UNITED STATES DISTRICT COURT
FOR THE SOUTHERN DISTRICT OF OHIO
WESTERN DIVISION
UNITED STATES
v. Case No. 1:24-mj-284
KIPTERREZ JAMES
Filed Under Seal
(a/k/a Kipp James, a/k/a Kip James)
AFFIDAVIT IN SUPPORT OF CRIMINAL COMPLAINT
I, Jason Greer, being first duly sworn, hereby depose and state as follows:
INTRODUCTION AND AGENT BACKGROUND
1. I am a Special Agent (“SA”) with Homeland Security Investigations (“HSI”),
Department of Homeland Security, Cincinnati – Assistant Special Agent in Charge Office. I
have been employed as a Special Agent with the HSI since September 2010. I attended the 16-
week Criminal Investigator Training Program (“CITP”) and the 8-week Immigration Customs
Enforcement Special Agent Training (“ICESAT”) at the Federal Law Enforcement Training
Center in Glynco, GA. During ICESAT training, I was trained in organized crime, fraud,
money laundering, drug trafficking, customs violations, and immigration investigations.
Additionally, I was previously employed as a Special Agent with the Drug Enforcement
Administration (“DEA”). I attended the sixteen-week DEA training academy and worked in a
DEA District Office in which I was trained and supervised in many aspects of investigations of
illegal narcotic trafficking and money laundering. My present responsibilities include the
investigation of violations of Titles 8, 18, 19, 21, and 26 of the United States Code and related
offenses. I have conducted and participated in numerous investigations involving financial
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crimes and have focused attention on the detection and apprehension of individuals violating
both federal and state laws.
2. I am familiar with the facts and circumstances of this case. The information
contained in this affidavit is either personally known to me, based upon my interview of various
witnesses and review of various records and publicly available information, or has been relayed
to me by other agents or sworn law enforcement personnel. Because this affidavit is being
submitted for the limited purpose of obtaining a criminal complaint and arrest warrant, I have not
included each and every fact known to me concerning the investigation. I have set forth only
those facts that I believe are necessary to establish probable cause to support the requested
complaint and arrest warrant.
3. Based on my training and experience and the facts as set forth in this affidavit,
there is probable cause to believe that violations of 18 U.S.C. § 1001 (False Statements) have
been committed by KIPTERREZ JAMES (a/k/a Kipp James, a/k/a Kip James).
PROBABLE CAUSE
4. On December 1, 2009, KIPP JAMES was sentenced to 92 months in prison
(consecutive to a state sentence) in Southern District of Ohio case 1:09-cr-005 for being a felon
in possession of a firearm. As he completed his sentence, he spent three months at the Talbert
House halfway house from January 28, 2021 to April 28, 2021.
5. On April 6, 2021, while he was at the Talbert House, JAMES applied online for a
Paycheck Protection Program loan, which was a COVID-19 pandemic relief program
administered by the Small Business Administration (“SBA”) that provided forgivable loans to
small businesses for job retention and certain other expenses. On the loan application, JAMES
claimed his business was called “Kip James.” He listed 485310 as the NAICS Code for his
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business. This code refers to taxi and ridesharing services. He claimed his business was
established in 2019. He claimed his business had $99,489 in gross income in 2019, when he
was actually incarcerated. He listed the business address as 2216 Vine Street, Cincinnati, Ohio
45219. This is the address of the Talbert House halfway house.
6. In support of the loan application, JAMES submitted a purported Green Dot bank
statement for account number xxxxxxxxx0912. However, in response to an inquiry during this
investigation, Green Dot responded that it had no record of this account number. Thus, the
purported bank statement appears to be a forgery.
7. In support of the loan application, JAMES uploaded a digital photo of his Ohio
driver’s license.
8. A search of Ohio’s Secretary of State website reveals no records of a business
with the name “KIP JAMES.” (JAMES did register a business called C&J Environmental
Services Inc. in 2023, but this was two years after he applied for the PPP loan.)
9. The PPP loan application was approved, and a loan of $20,725 was deposited on
April 17, 2021 into account xxx8060 at Kemba Credit Union. This account is held by JAMES.
He then spent the PPP money on personal expenditures, including the following:
- Several thousand dollars in cash withdrawals
- Several thousand dollars in transfers to his own CashApp account
- $439.00 at Vengeance (clothing store)
- $177.87 at Vengeance (clothing store)
- $480.79 at Exclusive513 (clothing store)
- $216.00 at Wendel’s (shoe store)
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- $118.14 at Red Lobster
- $139.06 at J Alexanders (restaurant)
- $183.26 at City Gear (shoe store)
- $40.00 at Kings Island
- $318.00 at Sole by Style (shoe store)
- $594.13 at Snaptravel MGM Grand
- $97.02 at JD (shoe store)
- $216.65 at Holiday House Liquors
- Expenditures in Las Vegas, NV from 5/28/2021 to 5/31/2021, including:
$272.67 at Maceoo Paris (clothing store)
$292.61 at Jimmy Choo (clothing store)
$227.59 at Jimmy Choo (clothing store)
$218.43 at Drai’s (nightclub)
$468.85 at Alamo (car rental)
$186.66 at MGM Grand.
10. JAMES applied for forgiveness of the PPP loan on August 23, 2021. On the
forgiveness application, he again claimed that his business was named “Kip James,” the
business address was 2216 Vine Street in Cincinnati, and the business NAICS code was 485310
(taxi/ridesharing). He falsely claimed that he spent $20,725 of the loan on payroll costs. He
falsely certified that he had complied with all PPP rules, including rules related to eligible uses
of PPP loan proceeds. The loan was forgiven.
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CONCLUSION
11. Based on the forgoing, I request that the Court issue the proposed complaint and arrest
warrant.
Respectfully submitted,
_____________________________
Jason Greer
Special Agent
Department of Homeland Security
Subscribed and sworn to before me on April 18
____, 2024.
_________________________________________
HON. KAREN
Karen L. L. LITKOVITZ
Litkovitz
UNITED STATES
United States MAGISTRATE
Magistrate Judge JUDGE
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