Motion to Seal Complaint and Proposed Order — United States v. Karen Chapon, No. 2:20-mj-00664

Summary

A [Proposed] Order Granting Government's Motion to Seal Complaint and the Government's Motion to Seal Complaint (Filed Under Seal) in United States of America v. Karen Chapon, aka "Karen Hannafious," Case 2:20-mj-00664-BNW, Document 2, filed 08/10/20, in the U.S. District Court for the District of Nevada. The order states that the Complaint, the Motion and the Court's Sealing Order shall be sealed until further Order of the Court. In the motion, the government states that the Complaint refers to an ongoing investigation and that the defendant is not yet in custody. It states that the defendant is charged with a scheme to defraud financial institutions by submitting false documentation in applications for federal Paycheck Protection Program loans.

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SEALED

Office of the United States Attorney
District of Nevada

501 Las Vegas Boulevard South,
Suite 1100

Las Vegas, Nevada 89101

(702) 388-6336
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Case 2:20-mj-00664-BNW Document2_ Filed 08/10/20 Page 2 of 4
FILED.

DATED: 1:49 pm, August 10,

U.S. MAGISTRATE JUD4
UNITED STATES DISTRICT COURT

DISTRICT OF NEVADA
UNITED STATES OF AMERICA, Case No. 2:20-mj-664-BNW
Plaintiff,
KAREN CHAPON,

aka “Karen Hannafious,”

Defendant.

[Proposed] Order Granting Government’s Motion to Seal Complaint
(Filed Under Seal)
Based on the pending Motion of the Government, and good cause appearing, IT IS
HEREBY ORDERED that the Complaint, the Motion, and this Court’s Sealing Order in

the above-captioned matter shall be sealed until further Order of the Court.

DATED this 10th day of August, 2929.

UNITED STATES MAGISSRs

ere

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2020
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Case 2:20-mj-00664-BNW Document2 _ Filed 08/10/20 Page 3of4

NICHOLAS A. TRUTANICH

United States Attorney FILED.
Nevada Bar Number 13644
Assistant United States Attorney U.S. MAGISTRATE JUDGE

501 Las Vegas Boulevard South, Suite 1100
Las Vegas, Nevada 89101
Tel: 702.388.6268

Attorneys for the United States

UNITED STATES DISTRICT COURT

DISTRICT OF NEVADA
UNITED STATES OF AMERICA, Case No. 2:20-mj-664-BNW
Plaintiff, Government’s Motion to Seal
Complaint
(Filed Under Seal)
KAREN CHAPON,

aka “Karen Hannafious,”

Defendant.

The United States of America, by and through Nicholas A. Trutanich, United States
Attorney, and Jessica Oliva, Assistant United States Attorney, respectfully moves this
Honorable Court for an Order sealing the Complaint, together with this Motion and the
Court’s Sealing Order, in the above-captioned matter until such time as the Court, or
another Court of competent jurisdiction, shall order otherwise.

It is necessary for the Complaint in this case to be sealed in light of the fact that it
makes reference to information regarding an ongoing investigation. Public disclosure of the
information in the Complaint might jeopardize the investigation because Defendant Karen
Chapon is not yet in custody. Chapon is charged with engaging in a scheme to defraud

financial institutions by submitting false documentation and information in applications for
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Case 2:20-mj-00664-BNW Document2 _ Filed 08/10/20 Page 4of4

federal Paycheck Protection Program loans. In making these applications, Chapon claimed
to be operating companies which had been generating substantial revenues and incurring
significant expenses before the COVID-19 pandemic. In reality, these companies do not
appear to have been operational at all. Should Chapon learn of this investigation before she
is arrested, Chapon could fabricate, alter or destroy evidence of these crimes.

To facilitate Chapon’s arrest, the Government respectfully requests that this Court
grant the Government’s motion and seal the Complaint in this case, as well as this Motion
and the Court’s Order on this Motion.

DATED this 10th day of August, 2020.

Respectfully submitted,

NICHOLAS A. TRUTANICH
United States Attorney

“JESSICA OLIVA
Assistant United States Attorney


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