Criminal Complaint — United States v. Justin Konikow (No. 2:25-cr-00729, C.D. Cal.)

Summary

A criminal complaint (AO 91) filed July 18, 2025 as Document 1 in United States v. Justin Konikow, Case No. 2:25-MJ-04469-DUTY (now 2:25-cr-00729-SPG), in the U.S. District Court for the Central District of California, charging wire fraud under 18 U.S.C. § 1343 between April 1, 2020 and February 18, 2022. It is signed by Robert Knight, Special Agent with the SBA Office of Inspector General, and attested by telephone before Magistrate Judge A. Joel Richlin. The affidavit alleges that Economic Injury Disaster Loan applications for Trendsetters LLC denied any criminal conviction although Konikow had pleaded guilty in January 2020 to mail fraud against the EDD in Case No. 2:19-cr-00605-JAK. It states the SBA approved the loan and three modifications for $89,000, $270,000, $183,300 and $262,700, at least $804,700 in total.

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“Criminal Complaint — United States v. Justin Konikow (No. 2:25-cr-00729, C.D. Cal.).” Original at archive.org. Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/complaint-no-2-25-cr-00729-dkt-1-c-d-cal-c0c798e0c5/, SHA-256 6db17e8b3eb6b4167b1a301fc3bed57c419a12fce0cf154e72f13c338efa22be.

Full text

Case 2:25-cr-00729-SPG Document 1 Filed 07/18/25 Page 1 of 11 Page ID #:1
AO 91 (Rev. 11/11) Criminal Complaint (Rev. by USAO on 3/12/20) ‫ ܆‬Original ‫ ܆‬Duplicate Original

LODGED
CLERK, U.S. DISTRICT COURT UNITED STATES DISTRICT COURT
7/18/2025 for the 7/18/2025
CENTRAL DISTRICT OF CALIFORNIA
MMC
BY: ____________BB______ DEPUTY
Central District of California CGM

United States of America

v.
Case No. 2:25-MJ-04469-DUTY
JUSTIN KONIKOW,

Defendant.

CRIMINAL COMPLAINT BY TELEPHONE
OR OTHER RELIABLE ELECTRONIC MEANS
I, the complainant in this case, state that the following is true to the best of my knowledge and belief.

On or about the dates of between April 1, 2020 and February 18, 2022, in the county of Los Angeles in the

Central District of California, and elsewhere, the defendant violated:

Code Section Offense Description

18 U.S.C. § 1343 Wire Fraud

This criminal complaint is based on these facts:

Please see attached affidavit.

_ Continued on the attached sheet.

/s/ Robert Knight, Special Agent
Complainant’s signature

Robert Knight, Special Agent, Office of Inspector
General, U.S. Small Business Administration
Printed name and title

Attested to by the applicant in accordance with the requirements of Fed. R. Crim. P. 4.1 by telephone.

Date: 07/18/2025
Judge’s signature
City and state: Los Angeles, California Hon. A. Joel Richlin, U.S. M i
agistrate Judge
Printed name and title

AUSA: Gregg Marmaro (x8500)
Case 2:25-cr-00729-SPG Document 1 Filed 07/18/25 Page 2 of 11 Page ID #:2

AFFIDAVIT
I, Robert Knight, being duly sworn, declare and state as

follows:

I. INTRODUCTION

1. I have been a federal agent for more than 18 years.

Since August 2021, I have been a Special Agent of the U.S. Small

Business Administration (“SBA”), Office of Inspector General

(“SBA-OIG”). Before that, I was a Special Agent for the U.S.

Postal Service, Office of Inspector General and the U.S. Army

Criminal Investigation Command.

2. Since graduating from the U.S. Army Criminal

Investigative Division’s Apprentice Special Agent Course, I have

over ten years of experience investigating various criminal

offenses including wire fraud, bank fraud, and money laundering.

As such, I have interviewed hundreds of witnesses and targets,

participated in the execution of numerous search and arrest

warrants relating to financial crimes, and worked with federal

prosecutors to prepare investigations for prosecution.

3. For the past four years, I have focused on

investigating crimes associated with SBA-related loan programs

including pandemic stimulus funding, sometimes referred to as

Covid-19 fraud. From reviewing dozens of pandemic stimulus loan

files and documents associated with those files such as

subpoenaed bank records and public records, I have become

familiar with the processing and vetting of applications under

the Economic Injury Disaster Loan program, among other pandemic-

related funding programs.

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4. Through my investigations, my training and experience,

and discussions with other law enforcement personnel, I have

become familiar with the tactics and methods employed by those

who conduct fraud schemes using fraudulent loan statements and

fabricated documents, money laundering, and identity theft,

among other federal offenses. These methods include, but are

not limited to, misrepresenting or concealing information about

applicants’ criminal histories; the use of corporate “shells,”

i.e., corporations that have been formed through the filing of

articles of incorporation but conduct no business; the use of

corporations or business entities that have the appearance of

legitimacy, such as by conducting some business or at least

advertising business, but are used to support fraudulent claims

for funding or to conceal the use of loan proceeds; and the

filing of applications with material false statements regarding

business activity, tax or regulatory filings, or the numbers of

employees (where, in many cases, there are none).

II. PURPOSE OF AFFIDAVIT

5. This affidavit is made in support of a criminal

complaint against, and request for issuance of an arrest warrant

for, JUSTIN KONIKOW (“KONIKOW”) for a violation of 18 U.S.C.

§ 1343 (wire fraud) (the “Subject Offense”).

6. The facts set forth in this affidavit are based on my

personal observations; my training and experience; witness

interviews that I have conducted; reports that I have read of

interviews conducted by other law enforcement agents; my review

of documents obtained from third parties, either by way of

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subpoena or voluntary submission, such as bank or business

records; my review of publicly-filed documents such as corporate

filings; Internet searches for open source information;

financial analyses or financial records summaries prepared by an

SBA analyst who told me that she reviewed and prepared such

analyses and summaries from bank and other financial records

obtained in this investigation, and whom I believe to be

qualified to make such analyses and summaries from having worked

with her for several years and having reviewed her work product

in other matters; and my review of documents created or amassed

by the SBA in connection with providing funding for the various

loans more fully described below. Accordingly, absent mention

below of specific attribution from any of the above-summarized

evidence, I have, solely for clarity, generally omitted

attribution for a specific fact.

7. My description of the offense conduct below is based

on my review of the above-summarized evidence and is provided

solely for the purpose of establishing probable cause to believe

that KONIKOW committed the Subject Offense. Accordingly, I have

not described all of the evidence that I have reviewed during

the course of this investigation and my omission of reference

toother evidence should be considered in that light.

8. Unless stated otherwise, all conversations and

statements described in this affidavit are related in substance

and/or in part only; all dates are “on or about” or

approximations; all amounts are rounded or close approximations;

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and the words “on or about” and “approximately” are omitted for

clarity.

III. SUMMARY OF PROBABLE CAUSE

9. I have probable cause to believe that KONIKOW

committed the Subject Offense by submitting and causing to be

submitted fraudulent applications to obtain hundreds of

thousands of dollars in pandemic stimulus funding by

fraudulently misrepresenting material facts about and concealing

his recent federal felony conviction. Namely, KONIKOW was

convicted in the Central District of California of mail fraud

for scheming to defraud the United States, the State of

California, and the Employment Development Department out of

money by filing false unemployment and disability insurance

claims using synthetic identities and fake companies, among

other material misstatements and omissions.

IV. PROBABLE CAUSE

A. The Economic Injury Disaster Loan Program

10. The Coronavirus Aid, Relief, and Economic Security
(“CARES”) Act was a federal law enacted in or about March 2020

that was designed to provide emergency financial assistance to

Americans suffering economic harm resulting from the COVID-19

pandemic. The CARES Act authorized taxpayer funds under the

Economic Injury Disaster Loan program (individually, an “EIDL,”

or collectively, “EIDLs”). The EIDL program provided low-

interest funding to small businesses, renters, and homeowners

affected by the COVID-19 pandemic.

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Case 2:25-cr-00729-SPG Document 1 Filed 07/18/25 Page 6 of 11 Page ID #:6

11. To obtain an EIDL, a qualifying business was required

to submit an application to the SBA, typically through an online

portal, and provide information about its operations, such as

the nature of the applicant’s business and the number of

employees. EIDL applicants were required to certify that all

information in the application as provided by the applicant or

on behalf of the applicant by their authorized representative

was true and correct. The applicant was also required to

provide information relating to the criminal history of the

applicant’s authorized representative.

12. Any funds paid under an EIDL were issued directly by

the SBA from CARES Act appropriations by Congress.

B. KONIKOW’S Recent, Prior Fraud Conviction in this
District

13. I reviewed publicly available documents and learned

the following:

a. On October 7, 2019, an Information charging

KONIKOW with one count of mail fraud was filed in the United

States District Court, Central District of California, in United

States v. Justin Konikow, Case No. 2:19-cr-00605-JAK.

b. In January 2020, KONIKOW pled guilty pursuant to

a plea agreement in which KONIKOW admitted to owning two

companies that KONIKOW admitted did not do any business; using

stolen identities and submitting phony wage reports with the

California Employment Development Department (“EDD”); and

submitting false unemployment insurance or disability insurance

(“UI/DI”) claims with the EDD for fake employees to obtain

5
Case 2:25-cr-00729-SPG Document 1 Filed 07/18/25 Page 7 of 11 Page ID #:7

benefits to personally use. KONIKOW admitted that he

fraudulently obtained $253,008 of EDD money.

c. KONIKOW was allowed to remain on bond pending his

sentencing, with a condition that included that he obey all

laws.

d. In January 2021, Hon. John A. Kronstadt

sentenced KONIKOW to 35 months’ imprisonment on KONIKOW’s mail

fraud conviction with the last six months to be served on home

confinement, to be followed by 3 years of supervised release,

and ordered him to pay restitution of $253,000, with $10,000 due

immediately. KONIKOW asked for and received an approximately

six-month period of delay to surrender, to July 6, 2021.

e. In June 2021, KONIKOW filed an unopposed request

to delay his surrender to accommodate six to nine months’

physical therapy to recover from a March 2021 snowboarding

accident. (Dkts. 44, 46 in CR 19-605-JAK.) Defendant

surrendered to the Bureau of Prisons in February 2022. (Dkt.

48, Id.)

f. In September 2023, KONIKOW was released from

prison to home confinement, and approximately six months

thereafter began his three-year period of supervised release.

In August 2024, KONIKOW’s probation officer filed a petition

against him for multiple violations of supervised release

including failing to pay restitution despite receiving hundreds

of thousands of dollars in cash from the sale of undisclosed

assets, failing to disclose business ownership, and failing to

first obtain permission to leave the district, no less to repair

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undisclosed real estate assets. (Dkts. 78, 86, Id.). Such

violations specifically included KONIKOW’s unreported receipt of

$82,875 ten days before his release from prison that KONIKOW did

not pay over in the face of Judge Kronstadt’s order that KONIKOW

make an immediate restitution payment at sentencing, which he

did not. (Dkt. 86, Id., at 7:25-27, 8:1-10.) Judge Kronstadt

found KONIKOW violated his supervised release terms and

sentenced KONIKOW to five months’ imprisonment, to be followed

by two years of supervised release. (Dkts. 90,91, Id.) KONIKOW

remains on federal supervision to this day.

C. KONIKOW’s EIDL Fraud Based on Misrepresenting and
Concealing His Recent Criminal History

14. I reviewed the SBA file for an EIDL and EIDL

modifications (loan increases) made to an entity called

Trendsetters LLC (“Trendsetters”) and learned the following:

a. On April 1, 2020, an EIDL application was

submitted online, through a server located in Virginia, on

behalf of Trendsetters. The application identified KONIKOW as

Trendsetter’s 100% owner. KONIKOW was identified by his true

name, true date of birth, and true residence address matching

the corresponding information of his driver’s license. The

application stated that both Trendsetters and KONIKOW shared the

same address, a residence located in Ontario, California, within

the Central District of California, matching that of KONIKOW’s

residence as stated on his driver’s license. (I know from

reviewing California corporate filings that Trendsetters was

incorporated in the State of California in 2017 and that KONIKOW

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was identified in its initial Statement of Information, filed on

May 30, 2017, as its sole manager and its chief executive

officer.)

b. The April 1, 2020 EIDL application contained the

representations that neither the business nor a “listed owner”

(i.e., KONIKOW, who was listed on the application as

Trendsetter’s sole owner) were “presently subject to an

indictment, criminal information, arraignment, or other means by

which formal criminal charges are brought in any jurisdiction”

nor had the business or a “listed owner” (i.e., KONIKOW) “for

any criminal offense [] ever been convicted, plead guilty, plead

nolo contendere, been placed on pretrial diversion, or been

placed on any form of parole or probation[.]”

c. Three EIDL modifications to increase the total

EIDL proceeds were submitted between 2021 and 2022, each

identifying KONIKOW as Trendsetter’s sole owner and authorized

representative. Each modification application contained a

certification that all representations in the loan application

(including in the original application) were true, correct, and

complete, under penalty of perjury. None of the modification

applications provided any information that KONIKOW had suffered

any criminal conviction.

15. The SBA approved the EIDL and each modification

application and wire-transferred the loan proceeds into a Chase

bank account identified on the applications as ending in 1692

(“Chase 1692”) in the amounts of, respectively, $89,000;

$270,000; $183,300; and $262,700.

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Case 2:25-cr-00729-SPG Document 1 Filed 07/18/25 Page 10 of 11 Page ID #:10

16. I reviewed subpoenaed bank records for the Chase 1692

and learned the following:

a. KONIKOW was the sole signatory for the account

and was identified on the bank signature card/account

application by his true name, date of birth, California driver’s

license and Social Security number. (His name and date of birth

matched those on the EIDL applications.)

b. All of the EIDL and EIDL modifications proceeds

were deposited into the Chase 1692. Specifically, for example,

on June 2, 2020, the SBA wire-transferred $88,990 into the Chase

1692 (the net amount requested for the original loan less the

application fee).

c. There were substantial wire transfers of EIDL

funds out of the Chase 1692, some in the thousands and within a

short period of time after the proceeds were deposited, for the

benefit of KONIKOW, including payments for his credit card

accounts, car payments, and an approximately $47,000 transfer to

his solely owned Robinhood stock trading account.

17. Based on my training and experience, I know that the

SBA relied at the relevant time on applicants’ representations

regarding their and their owners’ criminal histories,

particularly the lack thereof (and in particular, the lack of

any recent convictions, pending criminal charges, and/or fraud-

related convictions), and that such representations were

material to the SBA’s decision whether to issue a loan. I also

believe, based on my training and experience, that if the SBA

had known that KONIKOW had recently been convicted of a felony

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federal fraud offense, no less one involving a scheme to defraud

a government agency, the SBA would have denied KONIKOW’s

requests for EIDL funds.

D. Conclusion re: KONIKOW’s EIDL Fraud Scheme

18. As part of the EIDL fraud scheme against the SBA

described above, KONIKOW applied for and received at least

$804,700 in loans to which he was not entitled.

V. CONCLUSION

19. For all the reasons described above, there is probable

cause to believe that JUSTIN KONIKOW committed the Subject

Offense.

Attested to by the applicant in
accordance with the requirements
of Fed. R. Crim. P. 4.1
by telephone on this 18th day of
July, 2025.

HONORABLE A. JOEL RICHLIN
UNITED STATES MAGISTRATE JUDGE

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