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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.

Summary drafted by a model from the text of the original file linked on this page and checked by script against that text before publication. It is a navigation aid, not a reading of what the document proves. Where AI is used

Cite this document

“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/, SHA-256 66251f1282939547f224d30f2133d82d71e5a2920b526acc5c393bf351c535c5.

Full text

     . Case 1:24-cr-00279-JPW   Document 1   Filed 10/10/24    Page 1 of 27




                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.
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      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).




                                      24
      Case 1:24-cr-00279-JPW    Document 1   Filed 10/10/24   Page 25 of 27




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).




                                      25
      Case 1:24-cr-00279-JPW    Document 1   Filed 10/10/24   Page 26 of 27




                       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




                                     27


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