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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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Cite this document

“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

                                                 1
     Case: 1:24-cr-00039-MRB Doc #: 1 Filed: 04/18/24 Page: 3 of 6 PAGEID #: 3



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
                                                 2
      Case: 1:24-cr-00039-MRB Doc #: 1 Filed: 04/18/24 Page: 4 of 6 PAGEID #: 4



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)

                                                 3
     Case: 1:24-cr-00039-MRB Doc #: 1 Filed: 04/18/24 Page: 5 of 6 PAGEID #: 5



       -     $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.


                                                    4
      Case: 1:24-cr-00039-MRB Doc #: 1 Filed: 04/18/24 Page: 6 of 6 PAGEID #: 6



                                       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




                                               5


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