Indictment — United States v. Joshua White (M.D. Pa.)
Summary
A grand jury Indictment in United States v. Joshua White, Case 1:24-cr-00279-JPW, in the United States District Court for the Middle District of Pennsylvania, filed October 10, 2024. Count 1 charges conspiracy under 18 U.S.C. § 371 to commit wire fraud, bank fraud, false statements on loan applications and aggravated identity theft, from in or about March 2020 through in or about September 2022. The indictment alleges that the owner of Aluminum Alloys Mfg, LLC, with White and others, filed more than 120 PPP and EIDL applications for dormant Non-Operational Businesses, of which 42 were approved for more than $11,500,000. It alleges that White obtained personally identifying information from complicit and unwitting third parties for the applications, which included forged IRS Forms 941.
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“Indictment — United States v. Joshua White (M.D. Pa.).”
Original at archive.org. Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/court-filing-no-1-24-cr-00279-dkt-1-9506d29776/
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UNITED STATES DISTRICT COURT
MIDDLE DISTRICT OF PENNSYLVANIA
UNITED STATES OF AMERICA No. 1:24-CR- :;)19
V. (JUDGE ~e.T\G..lcJ\.~~)
JOSHUA WHITE,
Defendant.
INDICTMENT
FILED
THE GRAND JURY CHARGES: HARRISBURG, P/\
COUNT 1 OCT 10 2Q24
18 U.S.C. § 371 PER QOO .- -
DEPUTY CLG f'
(Conspiracy)
I. BACKGROUND
At times material to t his Indictment:
RELEVANT INDIVIDUALS AND ENTITIES
1. Creed White owned and operated an aluminum smelting
and processing business in Yoe, York County, Pennsylvania called
Aluminum Alloys Mfg, LLC ("Aluminum Alloys").
2. Joshua White was Creed White's son.
3. Joshua White lived on t he premises of Aluminum Alloys
and was employe d by or provided various services to Aluminum
Alloys at Creed White's direction.
Case 1:24-cr-00279-JPW Document 1 Filed 10/10/24 Page 2 of 27
4. Unindicted Coconspirator #1 was an employee of
Aluminum Alloys and was primarily responsible for service and sales.
5. Unindicted Coconspirator #2 was an employee of Aluminum
Alloys and was primarily responsible for bookkeeping and accounting
services.
6. In addition to Aluminum Alloys, Creed White owned or
controlled 18 other corporate entities, none of which had employees or
business operations. These dormant, non-operational entities included:
Aluminum Alloy Transportation & Repair LLC; American Scrap LLC;
Atlantic Coast Aluminum Inc. ; Atlantic Coast Aluminum LLC; Busche
Alum Tech LLC; Gettysburg Foundry Specialties Corp.; Hanover
Re source Recovery Corp.; House of Windsor LLC; Linamar USA, LLC;
Mahoney Foundries LLC ; Moran Materials Recycling Inc. ; Pinnacle
Cores LLC; Scrap Transport LLC; Tap Enterprises LLC; Tape
Enterprises American Aluminum Alloys LLC; Tristate Commodities
LLC; Wayne sboro Recycling LLC; and White Metal Recycling Company
LLC (collectively, "the Non-Operational Businesses") .
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THE PAYCHECK PROTECTION PROGRAM
7. The Paycheck Protection Program (PPP) was a COVID-19
pandemic relief program administered by the Small Business
Administration (SBA) , which provided forgivable loans to small
businesses for job retention and certain other expenses. The PPP
permitted participating third-party lenders to approve and disburse
SBA-backed PPP loans to cover payroll, fixed debts , utilities,
rent/mortgage obligations, accounts payable, and other bills incurred by
qualifying businesses during, and resulting from , the COVID-19
pandemic. PPP loans were fully guaranteed by the SBA.
8. To obtain a PPP loan, a qualifying business had to submit a
PPP loan application, which was signed by an authorized
representative of the business. The PPP loan application required the
business (through its authorized representative) to acknowledge the
program rules and make certain affirmative certifications to be eligible
to obtain a PPP loan. These certifications included that the business
was in operation on February 15, 2020, and either had employees for
whom it paid salaries and payroll taxes, or paid independent
contractors, as reported on a Form 1099-MISC.
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9. Moreover, the amount of the PPP loan that could be
approved under the PPP and implementing regulations was a function
of the applicant business's historical payroll costs, consisting of
compensation to its employees.
10. A business applying for a PPP loan was therefore required to
provide documentation to demonstrate its payroll expenses, such as
filed federal income tax documents. The applicant for a PPP loan was
required to certify that the information included as part of the
application was true and correct and acknowledged that false or
fraudulent representations could subject the applicant to prosecution.
11. PPP loan applications were completed, signed, and
submitted or caused to be submitted electronically by the borrower.
The applications were received through SBA servers located in Virginia
and Oregon. Once approved, the business received the PPP loan
proceeds via an electronic funds transfer from the third-party lender to
a financial account under the control of the borrower business.
12. As noted, the proceeds of a PPP loan could be used only for
specific purposes, including payroll costs, costs related to continuation
of group healthcare benefits, mortgage interest payments (but not
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mortgage prepayments or principal payments), rent payments, utility
payments, interest payments on debt obligations that were incurred
before February 15, 2020, or for refinancing certain specified SBA
loans. The proceeds of a PPP loan were not permitted to be used by
borrowers to purchase real property or make capital improvements.
The loan proceeds were also not permitted to be used to purchase
consumer goods, automobiles, or to fund the borrower's ordinary day-
to-day living expenses unrelated to the specific authorized expenses.
THE ECONOMIC INJURY DISASTER LOAN PROGRAM
13. The Economic Injury Disaster Loan (EIDL) Program was an
existing disaster-related program that was expanded by the
Coronavirus Aid, Relief, and Economic Security ("CARES") Act of
March 2020. The EIDL program was administered by the SBA and
provided low-interest financing (including forgivable advances of up to
$10,000) to small businesses and other eligible entities experiencing
substantial financial disruption resulting from the COVID-19
pandemic.
14. To qualify for an EIDL, an applicant business had to meet
certain criteria, including, among other things , that it was in operation
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prior to the pandemic, and had regular operating expenses, which
would have been paid if not for the COVID-19 pandemic. Moreover, the
amount of the loan that could be approved under the EIDL program
typically was a function of the applicant's working capital.
15. To qualify for an EIDL, an applicant business was required
to submit an application directly to the SBA and provide information
about the business's operations, such as the number of employees, gross
revenues for the 12-month period preceding the disaster, and cost of
goods sold in the same 12-month period. In the case of EIDLs for
COVID-19 relief, the 12-month period was January 31, 2019, to
January 31 , 2020. The applicant was also required to certify that all
the information in the application was true and correct to the best of the
applicant's knowledge.
16. EIDL applications were submitted directly to the SBA via
an online portal and processed by the agency with support from a
government contractor. If the application was approved, the amount of
the loan was based, in part, on the information the applicant provided
about employment, revenue , and costs of goods sold. Any funds issued
as part of an EIDL came directly from the United States Treasury.
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17. EIDL applications were received and processed using
computer servers located in the states of Iowa, Virginia, and
Washington. EIDL disbursements were initiated by the SBA using
computer servers located in the state of Colorado, which transmitted
the payment information to the United States Treasury using computer
servers located in the state of Virginia.
18. EIDL proceeds could be used only to pay fixed debts, payroll,
accounts payable, and other bills that could have been paid had the
disaster not occurred; however, such loan proceeds were not intended to
replace lost sales or profits or for expansion of a business.
II. THE CONSPIRACY AND ITS OBJECTS
19. Beginning in or about March 2020, and continuing through in
or about September 2022, in the Middle District of Pennsylvania, and
elsewhere, the defendant,
JOSHUA WHITE,
together with Creed White, Unindicted Coconspirator #1, Unindicted
Coconspirator #2, and others known and unknown to the Grand Jury,
did knowingly conspire and agree with each other to commit the
following offenses against the United States, all in violation of 18
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U.S.C. § 371:
a. Wjre Fraud-that is, knowingly to devise a scheme and
artifice to defraud financial institutions, the SBA, and other lenders,
and to obtain money and property by means of materially false and
fraudulent pretenses, representations, and promises, and for the
purpose of executing such scheme to transmit and cause to be
transmitted by means of wire communication in interstate and foreign
commerce , any writings, signs, signals, pictures, and sounds, in
violation of Title 18, United States Code, Section 1343;
b. Bank Fraud-that is, to knowingly devise , and intend to
devise , a scheme and artifice to defraud financial institutions, and to
obtain and attempt to obtain by means of materially false and
fraudulent pretenses, representations, and promises, moneys, funds ,
credits, assets, securities, and other property owned by, or under the
custody or control of a financial institution, in violation of Title 18,
United States Code, Section 1344;
c. False Statements on Loan AppHca6on~that is, for the
purpose of influencing the action of financial institutions and the SBA,
in connection with loan applications, knowingly to make false
statements and reports concerning revenue , payroll, number of
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employees, and to supply false and fictitious documents in support
thereof, in violation of Title 18, United States Code , Section 1014; and
d. Aggravated Identity Theft-that is, during and in relation to
any violation of Title 18, United States Code, Sections 1343 (wire fraud)
and 1344 (bank fraud) , knowingly to transfer, possess, and use , without
lawful authority, a means of identification of another person, in
violation of Title 18, United States Code, Section 1028A.
20. It was a purpose and object of the scheme and conspiracy for
Joshua White and his coconspirators to fraudulently obtain moneys,
funds , credits, assets, and other property owned by, and under the
custody and control of (a) financial institutions-namely, PPP loan
proceeds-and (b) the SBA through the EIDL program, through
materially false pretenses, representations, and promises.
III. MANNER AND MEANS OF THE CONSPIRACY
The conspiracy was accomplished, in part, by the following
manner and means:
21. It was part of the conspiracy that Creed White filed and
caused others to file , by means of the internet and interstate wires,
more than 120 applications for PPP loans and EIDLs with third-party
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intermediary lenders and the SBA on behalf of the Non-Operational
Businesses. Of these applications, 42 PPP loan and EIDL applications
were approved, for more than $11,500,000 in funds that were
transferred by interstate wires into accounts that Creed White owned
or controlled.
22. It was further part of the conspiracy that Joshua White,
acting at Creed White's direction, obtained personally identifying
information from both complicit and unwitting third parties that he and
Creed White and their coconspirators knowingly transferred, possessed,
and used without lawful authority in the applications for PPP loans and
EIDLs.
23. It was further part of the conspiracy that Joshua White and
Creed White made and caused others to make, by means of the
internet and interstate wires, material misrepresentations in the PPP
loan applications filed with third-party intermediary lenders and
FDIC-insured financial institutions, and in the EIDL applications filed
with the SBA.
24. For example , the PPP and EIDL applications Creed White ,
Joshua White, and their coconspirators submitted and caused to be
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submitted included material misrepresentations that the individuals
listed as applicants on the loan applications owned, controlled, or
operated the Non· Operational Businesses, when in fact they did not.
The applications also included material misrepresentations that the
Non-Operational Businesses under Creed White's and Joshua White's
control had actual business operations, when in fact they did not.
25. As further example , Joshua White, Creed White, and their
coconspirators caused the PPP loan and EIDL applications to include
material misrepresentations and false supporting documents, including
false information attesting to the number of employees purported to be
employed by the Non-Operational Businesses, fabricated bank and
other financial statements that Joshua White, Creed White, and their
coconspirators created to give the appearance that they were
legitimate business records, and false payroll information.
26. The applications further included material
misrepresentations and certifications that the PPP and EIDL funds
would be used for payroll costs, business-related purposes, and other
authorized expenditures, when Joshua White, Creed White , and
their coconspirators knew that the funds would not be used for those
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purposes.
27. It was further part of the conspiracy that Joshua White,
Creed White, and their coconspirators created, caused to be created,
sent, and caused others to send, by means of the internet and
interstate wires, forged and fraudulent documents to third-party
intermediary lenders and FDIC-insured financial institutions, in
support of PPP loan applications, and to the SBA in support of EIDL
applications.
28. For example, Creed White, Joshua White and their
coconspirators created, caused to be created, sent, and caused others to
send, forged and falsified Internal Revenue Service documents,
including Forms 941 federal employment tax documents. Those forged
and falsified IRS documents contained material misrepresentations,
including false employee headcount information, fabricated information
concerning employee wages paid, taxes withheld, taxes remitted to the
IRS, income , gross receipts, costs of goods sold, and business expenses.
Moreover, the forged and falsified IRS documents were represented as
having been filed with the IRS, when in fact they were not.
29. It was further part of the conspiracy that Joshua White,
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Creed White , and their coconspirators caused the proceeds of
fraudulently obtained PPP loans and EIDLs to be deposited, by
means of interstate wires or other transfers, into bank accounts in
Joshua White's or Creed White's names or under their control.
30. It was further part of the conspiracy that Creed White
transferred and caused others to transfer the proceeds of fraudulently
obtained PPP loans and EID Ls, including by means of the internet and
interstate wires.
31. It was further part of the conspiracy that Creed White used
and caused others to use the proceeds of fraudulently obtained PPP and
EIDL funds for impermissible purposes, including to make capital
improvements to Aluminum Alloys, to purchase business vehicles and
other heavy equipment, to pay off business debts (including a mortgage
on a building), to purchase aluminum scrap, and to make other
unauthorized expenditures for his personal benefit.
32. It was further part of the conspiracy that Joshua White used
proceeds of fraudulently obtained PPP loans for impermissible purposes,
including for his personal benefit and enrichment.
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IV. ACTS IN FURTHERANCE OF THE CONSPIRACY
In furtherance of the conspiracy and to effect the objects of the
conspiracy, the following overt acts, among others, were committed in
the Middle District of Pennsylvania and elsewhere:
33. On or about May 15, 2020, Creed White and Joshua White
submitted via the internet a $126,300 PPP loan application to Citizens
Bank on behalf of Busche Alum Tech LLC ("Busche"). In Busche's PPP
loan application, Creed White and Joshua White falsely represented
that Joshua White owned Busche, when in fact Creed White did. In
Busche's PPP loan application, Creed White and Joshua White falsely
represented that Busche had ongoing business operations and
employees, knowing that Busche had no business operations and no
employees. In Busche's PPP loan application, Creed White and Joshua
White falsely attested that the PPP loan proceeds would be used for
expenses authorized under the PPP when, in fact, they intended to use
the loan proceeds for unauthorized purposes. In addition, Joshua
White and Creed White negotiated an agreed-upon payment that
Joshua White would receive for allowing Creed White to use his
personally identifying information as part of the Busche PPP loan
application.
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34. On or about May 18, 2020, Citizens Bank approved Busche's
PPP loan application and deposited approximately $126,300 into Creed
White's Citizens Bank account ending in -2117. On an unknown date
in 2020, Creed White paid Joshua White at least $30,000 out of the
proceeds obtained from Busche's PPP loan, which was an unauthorized
use of the PPP loan proceeds.
35. On or about May 17, 2020, Creed White , with Joshua
White's knowledge and assistance , submitted via the internet a
$130,000 PPP loan application to Cross River Bank on behalf of
Linamar USA LLC ("Linamar"). In the PPP loan application, Creed
White falsely represented that a third party with the initials J.S.-an
actual person- owned Linamar, when in £act Creed White did. In the
PPP loan application, Creed White falsely represented that Linamar
had 16 employees and an average monthly payroll of $52,000, when he
and Joshua White knew that Linamar had no employees and no
monthly payroll. In support of the loan application, Creed White
included false and fraudulent IRS Forms 941 that he and other
coconspirators created. To make it appear that J.S. owned Linamar,
Joshua White and Creed White knowingly obtained J.S.'s Social
Security Number and used J.S .'s Social Security Number as part of the
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Linamar PPP loan application.
36. On or about May 19, 2020, Cross River Bank approved
Linamar's PPP loan and deposited approximately $130,000 into Creed
White's Citizens Bank account ending -2001.
37. On or about June 23, 2020, Creed White, with Joshua
White's knowledge and assistance , submitted via the internet a PPP
loan application to First Home Bank and an EIDL application to the
SBA on behalf of Atlantic Coast Aluminum Inc. In the PPP loan and
EIDL applications, Creed White falsely represented that a third party
with the initials E.S.-an actual person-owned Atlantic Coast
Aluminum, when in fact Creed White did. In the PPP loan and EIDL
applications, Creed White falsely represented that Atlantic Coast
Aluminum had ongoing business operations, employees, and payroll
expenses, when he and Joshua White knew that Atlantic Coast
Aluminum had no business operations, employees, or payroll. To make
it appear that E.S. owned Atlantic Coast Aluminum, Joshua White and
Creed White knowingly obtained E.S.'s Social Security Number and
Pennsylvania driver's license and knowingly used E.S.'s Social Security
Number and driver's license as part of Atlantic Coast Aluminum's PPP
loan and EIDL applications without lawful authority.
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38. On or about June 25, 2020, the SBA issued Atlantic Coast
Aluminum a $10,000 EIDL grant and caused $10,000 to be deposited
into Creed White's Citizens Bank account ending in -7929.
39. On or about July 21, 2020, Creed White , with Joshua
White's knowledge and assistance, submitted via the internet a
$402,500 PPP loan application to Newtek Small Business Finance on
behalf of Tape Enterprises-American Aluminum Alloys LLC ("Tape
Enterprises"). In the PPP loan application, Creed White falsely
represented that a third party with the initials B.G.-an actual
person-owned Tape Enterprises, when in fact Creed White did. In
Tape Enterprise's PPP loan application, Creed White falsely
represented that Tape Enterprises had ongoing business operations,
employees, and payroll expenses, when he and Joshua White knew that
Tape Enterprises had no business operations, employees, or payroll. To
make it appear that E.G. owned Tape Enterprises, Joshua White and
Creed White knowingly obtained B.G.'s Social Security Number and
Pennsylvania driver's license and knowingly used B.G.'s Social Security
Number and driver's license as part of Tape Enterprises's PPP loan
application without lawful authority.
40. On or about July 28, 2020, Newtek Small Business Finance
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approved Tape Enterprises's PPP loan application and caused
approximately $402,500 to be deposited into Creed White's Radius
Bank account ending in ·2292.
41. On or about August 4, 2020, Creed White, with Joshua
White's knowledge and assistance , submitted via the internet a
$419,460 PPP loan application to Lending Club Bank on behalf of
American Scrap LLC ("American Scrap"). In American Scrap's PPP
loan application, Creed White falsely represented that a third party
with the initials A.G.-an actual person-owned American Scrap, when
in fact Creed White did. In American Scrap's PPP loan application,
Creed White falsely represented that American Scrap had ongoing
business operations, employees, and payroll expenses, when he and
Joshua White knew that American Scrap had no business operations,
employees, or payroll. To make it appear that A.G. owned American
Scrap, Joshua White and Creed White knowingly obtained A.G.'s Social
Security Number and Pennsylvania driver's license and knowingly
used A.G.'s Social Security Number and driver's license as part of
American Scrap's PPP loan application without lawful authority.
42. On or about August 18, 2020, Lending Club Bank approved
American Scrap's PPP loan application and caused approximately
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$419,460 to be deposited into Creed White's Radius Bank account
ending in -8729.
43. On or about March 23, 2021 , Joshua White, with Creed
White's knowledge and assistance, submitted via the internet a
$175,000 PPP loan application to Northeast Bank on behalf of Tristate
Commodities LLC ("Tristate"). In Tristate's PPP loan application,
Joshua White falsely represented that Tristate had ongoing business
operations, 21 employees, and an average monthly payroll of $70,000,
knowing that Tristate had no business operations, employees, or
payroll. In Tristate's PPP loan application, Joshua White falsely
represented that the PPP loan proceeds would be used to retain
workers, maintain payroll, and to pay for other authorized expenses,
knowing that he intended to use the proceeds for his own personal
benefit and enrichment.
44. On or about March 31, 2021 , Northeast Bank caused
approximately $175,000 to be deposited into Joshua White's Citizens
Bank account ending in -3407.
All in violation of Title 18, United States Code, Section 371.
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THE GRAND JURY FURTHER CHARGES:
COUNT2
18 U.S.C. § 1344
(Bank Fraud)
45 . The facts alleged in paragraphs 1 through 18, 20 through 32,
and 43 through 44 are incorporated here.
46. From on or about March 23, 2021 , through on or about March
31, 2021, the defendant,
JOSHUA WHITE,
knowingly devised a scheme and artifice to defraud Northeast Bank, a
financial institution as defined in Title 18, United States Code, Section
20, and to obtain moneys and funds owned by and under the custody and
control of Northeast Bank, by means of materially false and fraudulent
pretenses, representations, and promises, and by the omission of
material facts (the "bank fraud scheme").
47. At times material to the bank fraud scheme, Joshua White
was the sole owner of a Pennsylvania limited liability company called
Tristate Commodities LLC.
48. Northeast Bank participated as a lender in the PPP program.
49. On or about March 23, 2021, for the purpose of executing and
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attempting to execute the bank fraud scheme , Joshua White signed and
submitted to Northeast Bank an application for a PPP loan in the name
of Tristate Commodities LLC, which requested a PPP loan in the amount
of $175,000, and which falsely represented that Tristate Commodities
LLC had 21 employees and an average monthly payroll of $52,000.
All in violation of Title 18, United States Code, Sections 1344 and 2.
THE GRAND JURY FURTHER CHARGES:
COUNT3
18 U.S.C. § 1014
(False Statements on Loan Application)
50. The facts alleged in paragraphs 1 through 18, 20 through 32,
and 43 through 44 are incorporated here.
51. On or about March 23 , 2021 , in the Middle District of
Pennsylvania, the defendant,
JOSHUA WHITE,
knowingly made a false statement for the purpose of influencing the
action of Northeast Bank, an institution the deposits of which were
insured by the Federal Deposit Insurance Corporation, in connection
with Tristate Commodities LLC's application for a PPP loan, by falsely
representing that Tristate Commodities LLC had 21 employees and an
average monthly payroll of $52,000.
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In violation of Title 18, United States Code, Sections 1014 and 2.
THE GRAND JURY FURTHER CHARGES:
COUNT4
18 U.S.C. § 1028A
(Aggravated Identity Theft)
52. The facts alleged in paragraphs 1 through 18, 20 through 32,
and 35 through 36 are incorporated here.
53. On or about May 17, 2020, in the Middle District of
Pennsylvania, the defendant,
JOSHUA WHITE,
did knowingly transfer, possess, and use , without lawful authority, a
means of identification of J.S., a person known to the Grand Jury, during
and in relation to a felony violation enumerated in 18 U.S.C. § 1028A(c), to
wit, bank fraud, knowing that the means of identification belonged to
another actual person.
In violation of Title 18, United States Code, Section 1028A(a)(l).
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THE GRAND JURY FURTHER CHARGES:
COUNTS
18 U.S.C. § 1028A
(Aggravated Identity Theft)
54. The facts alleged in paragraphs 1 through 18, 20 through 32,
and 37 through 38 are incorporated here.
55. On or about June 23, 2020, in the Middle District of
Pennsylvania, the defendant,
JOSHUA WHITE,
did knowingly transfer, possess, and use, without lawful authority, a
means of identification of E.S., a person known to the Grand Jury, during
and in relation to a felony violation enumerated in 18 U.S.C. § 1028A(c), to
wit, bank fraud, knowing that the means of identification belonged to
another actual person.
In violation of Title 18, United States Code, Section 1028A(a)(l).
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THE GRAND JURY FURTHER CHARGES:
COUNT6
18 U.S.C. § 1028A
(Aggravated Identity Theft)
56. The facts alleged in paragraphs 1 through 18, 20 through 32,
and 39 through 40 are incorporated here.
57. On or about July 21 , 2020, in the Middle District of
Pennsylvania, the defendant,
JOSHUA WHITE,
did knowingly transfer, possess, and use , without lawful authority, a
means of identification of B.G. , a person known to the Grand Jury, during
and in relation to a felony violation enumerated in 18 U.S.C. § 1028A(c), to
wit, bank fraud, knowing that the means of identification belonged to
another actual person.
In violation of Title 18, United States Code, Section 1028A(a)(l).
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THE GRAND JURY FURTHER CHARGES:
COUNT7
18 U.S.C. § 1028A
(Aggravated Identity Theft)
58. The facts alleged in paragraphs 1 through 18, 20 through 32,
and 41 through 42 are incorporated here .
59. On or about August 4, 2020, in the Middle District of
Pennsylvania, the defendant,
JOSHUA WHITE,
did knowingly transfer, possess, and use , without lawful authority, a
means of identification of A.G. , a person known to the Grand Jury, during
and in relation to a felony violation enumerated in 18 U.S.C. § 1028A(c), to
wit, bank fraud, knowing that the means of identification belonged to
another actual person.
In violation of Title 18, United States Code, Section 1028A(a)(l).
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FORFEITURE ALLEGATION
60. The allegations contained in paragraphs 1 through 59 of this
Indictment are realleged and incorporated here for the purpose of alleging
forfeitures pursuant to Title 18, United States Code, Sections 98l(a)(l)(C)
and 982(a)(l) , and Title 28, United States Code, Section 246l(c).
61. Upon conviction any of the offenses charged in Counts 1
through 7 of this Indictment, the defendant,
JOSHUA WHITE,
shall forfeit to the United States, pursuant to Title 18, United States
Code, Section 98l(a)(l)(C) and Title 28, United States Code, Section
246l(c), any property, real or personal, which constitutes or is derived
from proceeds obtained directly or indirectly from the commission of the
offense of which the person is convicted.
62. If any of the property, real or personal, which constitutes or is
derived from proceeds obtained directly or indirectly from the commission
of the offense of which the person is convicted:
a. cannot be located upon the exercise of due diligence;
b. has been transferred or sold to, or deposited with, a third
party;
c. has been placed beyond the jurisdiction of the court;
26
Case 1:24-cr-00279-JPW Document 1 Filed 10/10/24 Page 27 of 27
d. has been substantially diminished in value; or
e. has been commingled with other property which cannot
be divided without difficulty,
the United States of America shall be entitled to forfeiture of substitute
property pursuant to Title 18, United States Code, Section 982(b) , Title
21, United States Code, Section 853(p) , as incorporated by Title 28,
United States Code, Section 2461(c).
A TRUE BILL
GERARD M. KARAM
United States Attorney
CHRISTIAN T. HAUGSBY Date
Assistant United States Attorney
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