Information — United States v. Jontrell Wright (District of South Carolina, Entry Number 1)

Summary

Information filed May 25, 2022 as Entry Number 1 in United States of America v. Jontrell Wright, Case 2:22-cr-00455-DCN (CR. NO. 2:22-cr-455), U.S. District Court for the District of South Carolina, Charleston Division. Count 1, Conspiracy to Commit Wire Fraud under 18 U.S.C. § 371, charges that from in or around June 2020 to at least January 2021 the Defendant and others conspired to violate 18 U.S.C. § 1343 through false PPP loan applications, and alleges that Wright fraudulently obtained $561,700.00 in PPP loan funds. Count Two, Wire Fraud under 18 U.S.C. § 1343, alleges a PPP loan application for Wright & Sons in which BankVista approved a loan and approximately $433,000.00 was distributed on or about July 21, 2020. It alleges that the application claimed 21 employees with a monthly payroll of $173,235.00 and states a forfeiture.

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“Information — United States v. Jontrell Wright (District of South Carolina, Entry Number 1).” Original at ecf.scd.uscourts.gov. Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/court-filing-no-2-22-cr-00455-dkt-1-6ebd31a8cb/, SHA-256 8b28a86138a3ec3ff9b880b4684f85b78c5a0669c079d8c31c65004882d15fe9.

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2:22-cr-00455-DCN Date Filed 05/25/22 Entry Number 1 Page 1 of 10

IN THE DISTRICT COURT OF THE UNITED STATES
FOR THE DISTRICT OF SOUTH CAROLINA
CHARLESTON DIVISION

UNITED STATES OF AMERICA ) 2:22-cr-455
CR. NO.: ______________
)
) 18 U.S.C. § 2
vs. ) 18 U.S.C. § 371
) 18 U.S.C. § 1343
) 18 U.S.C. § 981(a)(1)(C)
JONTRELL WRIGHT ) 28 U.S.C. § 2461(c)
)

INFORMATION

THE UNITED STATES ATTORNEY CHARGES:

At times relevant to this Information:

The Defendant and Coconspirators

1. The Defendant, Jontrell Wright, was a citizen of the United States and resident of

South Carolina.

2. Lori Hammond, a/k/a Lori McCracken, a/k/a Lori Blakely, (“Hammond”) was a

citizen of the United States and resident of South Carolina.

3. Catherine (“Cassie”) Needham (“Needham”) was a citizen of the United States and

resident of South Carolina.

4. Christopher Conrad (“Conrad”) was a citizen of the United States and a resident of

South Carolina.

Background on the Paycheck Protection Program (“PPP”)

5. The United States Small Business Administration (“SBA”) was an executive

branch agency of the United States government that provided support to entrepreneurs and small

businesses. The mission of the SBA was to maintain and strengthen the nation’s economy by

enabling the establishment and viability of small businesses and by assisting in the economic
2:22-cr-00455-DCN Date Filed 05/25/22 Entry Number 1 Page 2 of 10

recovery of communities after disasters. As part of this effort, the SBA enabled and provided for

loans through banks, credit unions, and other lenders. These loans have government-backed

guarantees.

6. The Coronavirus Aid, Relief, and Economic Security (“CARES”) Act is a federal

law enacted in or around March 2020 designed to provide emergency financial assistance to the

millions of Americans who were suffering the economic effects caused by the COVID-19

pandemic. One source of relief provided by the CARES Act was the authorization of up to $349

billion in forgivable loans to small businesses for job retention and certain other expenses through

a program referred to as the Paycheck Protection Program (“PPP”). In or around April 2020,

Congress authorized over $300 billion in additional PPP funding.

7. The PPP allowed qualifying small businesses and other organizations to receive

PPP loans. Businesses were required to use PPP loan proceeds on payroll costs, interest on

mortgages, rent, and utilities. The PPP allowed the interest and principal on the PPP loan to be

entirely forgiven if the business spent the loan proceeds on these expense items within a designated

period of time and used a certain percentage of the PPP loan proceeds on payroll expenses.

8. The amount of a PPP loan that a small business may be entitled to receive was

determined by the number of employees employed by the business and the business’s average

monthly payroll costs.

9. In order to obtain a PPP loan, a qualifying business was required 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 in order to be eligible to obtain the PPP

loan. In the PPP loan application, the small business (through its authorized representative) had

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to state, among other things, its: (a) average monthly payroll expenses; and (b) number of

employees. These figures were used to calculate the amount of money the small business was

eligible to receive under the PPP. In addition, businesses applying for a PPP loan had to provide

documentation showing their payroll expenses.

10. The provisions of the CARES Act, in conjunction with an officially declared

disaster by the United States Government, also allowed for the SBA to provide Economic Injury

Disaster Loans (“EIDL”) funding to business owners negatively affected by the COVID-19

pandemic. The SBA Office of Disaster Assistance (“ODA”) controls the EIDL program and

maintains authority over all loans created and disbursed under the EIDL program. Pursuant to the

provisions governing the EIDL program, loan proceeds must be used by the business to pay certain

permissible expenses. The EIDL loans may be used to pay fixed debts, payroll, accounts payable,

and other bills that could have been paid had the COVID-19 disaster not occurred.

11. The PPP loan application requires the business (through its authorized

representative) to acknowledge the program rules and answer a series of questions in order to be

eligible to obtain the PPP loan, to include the following:

a. Within the last 5 years, for any felony, has the Applicant (if an individual) or any
owner of the Applicant 1) been convicted; 2) pleaded guilty; 3) pleaded nolo
contendere; 4) been placed on pretrial diversion; or 5) been placed on any form
of parole or probation (including probation before judgment)?
Above this question, the application states that if the answer is “Yes,” the loan will not be

approved.

12. In the PPP loan application, the small business (through its authorized

representative) must state, among other things, its: (a) average monthly payroll expenses; and (b)

number of employees. These figures are used to calculate the amount of money the small business

is eligible to receive under the PPP. In addition, businesses applying for a PPP loan must provide

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documentation showing their payroll expenses. Applicants must acknowledge the following by

initialing next to each statement:

a. The Applicant was in operation on February 15, 2020 and had employees for
whom it paid salaries and payroll taxes or paid independent contractors, as
reported on Form(s) 1099-MISC
b. The funds will be used to retain workers and maintain payroll or make mortgage
interest payments, lease payments and utility payments as specified under the PPP
Rule; I understand that if the funds are knowingly used for unauthorized purposes,
the federal government may hold me legally liable, such as for charges of fraud.
13. The SBA oversees the PPP. However, a PPP loan application must be processed by

a participating financial institution, most commonly, banks and credit unions (the lender). If a PPP

loan application is approved, the lender funds the PPP loan using its own monies, which are 100%

guaranteed by Small Business Administration (SBA). Data from the application, including

information about the borrower, the total amount of the loan, and the listed number of employees,

is transmitted by the lender to the SBA in the course of processing the loan.

14. PPP loan proceeds must be used by the business on certain permissible expenses -

payroll costs, interest on mortgages, rent, and utilities. The PPP allows the interest and principal

on the PPP loan to be entirely forgiven if the business spends the loan proceeds on these expense

items within a designated period of time (usually eight weeks of receiving the proceeds) and uses

at least 75% of the PPP loan proceeds on payroll expenses.

Relevant Entities

15. Wright & Sons Transport (“Wright & Sons”) is a registered business that is

currently in good standing with the South Carolina Secretary of State. According to documentation

from the South Carolina Department of Employment and Workforce, there are no employer

accounts on file with the name Wright & Sons. In PPP loan documents, Jontrell Wright claimed

sole ownership of Port Wright & Sons.

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Relevant Banks and Lenders

16. BankVista is a federally insured financial institution located in Sartell, Minnesota.

BankVista is an approved lender for PPP loans, and as such, was authorized to lend funds to

eligible borrowers under the terms of the PPP.

Overview of the Scheme

17. From in or around June 2020 through a date unknown to the United States Attorney

but up to at least January 2021, Hammond caused materially fraudulent PPP loan applications to

be submitted to federally insured financial institutions on behalf of herself and her associates,

Needham, Conrad, and Wright, to obtain PPP funds. In these applications, Hammond falsified her

identity, misrepresented the number of employees and payroll expenses of the entities seeking the

loans, attached fraudulent tax documents, and made numerous other false and misleading

statements.

18. Hammond assisted Needham, Conrad, and Jontrell Wright by filling out PPP loan

application documents containing materially false and fraudulent information and submitting them

to a Confidential Source (“CS”). CS would then submit the fraudulent loan applications to financial

institutions approved to loan funds to eligible borrowers under the terms of the PPP, in exchange

for a fee. All of the loan applications Hammond submitted on behalf of Needham, Conrad, and

Jontrell Wright contained false and fraudulent information about the number of employees and

corresponding payroll expenses.

19. Based on the false and fraudulent representations and submissions in the PPP loan

applications and other supporting documentation submitted by Hammond, Needham, Conrad, and

Jontrell Wright, with Hammond’s assistance and direction, the approved PPP lenders funded the

PPP loans.

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20. After the PPP loan funds were deposited into the respective accounts, Hammond,

Needham, Conrad, and Jontrell Wright used the funds for non-qualifying, non-business-related

purposes, in violation of the terms of the PPP loan program.

COUNT 1
Conspiracy to Commit Wire Fraud (18 U.S.C. § 371)

21. The allegations contained in paragraphs 1 through 20 are incorporated by reference

as if set forth fully herein.

22. From in or around June 2020 to and continuing until at least January 2021, in the

District of South Carolina and elsewhere, the defendant, JONTRELL WRIGHT, and others

knowingly and intentionally combined, conspired, confederated, agreed, and had a tacit

understanding to knowingly devise a scheme and artifice to defraud and to obtain money and

property by means of false and fraudulent pretenses, representations, and promises, transmitted or

caused to be transmitted by means of wire, radio, or television communication in interstate

commerce, any writings, signs, signals, pictures or sounds for the purpose of executing the scheme

and artifice, in violation of Title 18, United States Code, Section 1343;

Object of the Conspiracy

23. The object of the conspiracy was for the Defendant, JONTRELL WRIGHT, to

provide false representations on PPP loan applications submitted to federally insured financial

institutions to obtain money and property. In the loan applications, JONTRELL WRIGHT

misrepresented the number of employees and payroll expenses of the entities seeking the loans,

attached fraudulent tax documents, and made numerous other false and misleading statements.

Overt Acts

24. In furtherance of the conspiracy, the Defendant, JONTRELL WRIGHT, and

others known and unknown to the United States Attorney, including Hammond, committed the

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following overt acts in the District of South Carolina, by submitting the following loan application

on behalf of the business as set forth below:

Applicant Business Name Date of Loan Amount Lender
Funding
Wright Wright & Sons July 21, $433,000.00 BankVista
Transport 2020

25. JONTRELL WRIGHT fraudulently obtained $561,700.00 in PPP loan funds.

All in violation of Title 18, United States Code, Sections 371 and 2.

COUNT TWO
Wire Fraud (18 U.S.C. § 1343)

The Scheme to Defraud

26. The allegations contained in paragraphs 1 through 20 and 23 through 25 of this

Information are incorporated herein by reference.

27. That beginning in or about May 2020, and continuing until in or about January

2021, in the District of South Carolina and elsewhere, the Defendant, JONTRELL WRIGHT,

and others known and unknown to the United States Attorney, knowingly devised a scheme and

artifice to defraud and to obtain money and property by means of false and fraudulent pretenses,

representations and promises, and during such period, knowingly transmitted and caused to be

transmitted in interstate commerce, by means of wire communications, certain electronic signals,

for the purpose of executing the scheme and artifice to defraud, in violation of Title 18, United

States Code, Section 1343.

Manner and Means of the Scheme and Artifice to Defraud

28. It was part of the scheme that Hammond electronically submitted a PPP loan

application, on behalf of and at JONTRELL WRIGHT’S direction, to CS, who in turn submitted

the loan application to BankVista. In the loan application, JONTRELL WRIGHT requested a

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PPP loan for Wright & Sons. According to the loan application, Wright & Sons is located at 606

Fourwinds Rd., Holly Hill, SC. Wright & Sons claimed 21 employees with a monthly payroll of

$173,235.00. JONTRELL WRIGHT is listed as 100% owner, signed as the authorized

representative, and included a photocopy of his driver’s license as required with the application.

29. In the loan application, JONTRELL WRIGHT and Hammond included material

fraudulent and false representations and submissions. Specifically, JONTRELL WRIGHT and

Hammond fraudulently inflated the number of employees and the corresponding payroll expenses.

JONTRELL WRIGHT and Hammond submitted a false business address for Wright & Sons and

attached fraudulent tax documents to the loan application. BankVista approved the loan application

for Wright & Sons and submitted the loan application to the SBA for funding.

30. On or about July 21, 2020, based on JONTRELL WRIGHT and Hammond’s

fraudulent and false representations and submissions, the U.S. Treasury or SBA approved the loan

and distributed approximately $433,000.00 in PPP loan funds to JONTRELL WRIGHT’S

personal bank account.

31. After JONTRELL WRIGHT received the funds, he used the funds for non-

qualifying, non-business-related purposes, in violation of the terms of the PPP loan program,

including by making large cash withdrawals and by purchasing a golf cart, among other personal

purchases.

All in violation of Title 18, United States Code, Section 1343.

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2:22-cr-00455-DCN Date Filed 05/25/22 Entry Number 1 Page 9 of 10

FORFEITURE

CONSPIRACY/WIRE FRAUD:

Upon conviction for violation of Title 18, United States Code, Sections 371 and 1343 as

charged in this Information, the Defendant, JONTRELL WRIGHT, shall forfeit to the United

States any property, real or personal, constituting, derived from or traceable to proceeds the

Defendant obtained directly or indirectly as a result of such offenses.

PROPERTY:

Pursuant to 18 U.S.C. § 981(a)(1)(C) and 28 U.S.C. § 2461(c), the property which is subject to

forfeiture upon conviction of the Defendant for the offenses charged in this Information includes,

but is not limited to, the following:

Cash Proceeds/Forfeiture Judgment:

A sum of money equal to all property the Defendant obtained as a result of
the wire fraud offenses charged in this Information, and all interest and
proceeds traceable thereto as a result for his violation of 18 U.S.C. §§ 371
and 1343.

SUBSTITUTION OF ASSETS:

If any of the property described above as being subject to forfeiture, as a result of any act

or omission of the Defendant:

(a) cannot be located upon the exercise of due diligence;
(b) has been transferred or sold to, or deposited with, a third person;
(c) has been placed beyond the jurisdiction of the Court;
(d) has been substantially diminished in value; or
(e) has been commingled with other property which cannot be subdivided
without difficulty;

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it is the intent of the United States, pursuant to Title 21, United States Code, Section 853(p), as

incorporated by 18 U.S.C. § 982(b)(1) to seek forfeiture of any other property of Defendant up to

an amount equivalent to the value of the above-described forfeitable property;

Pursuant to Title 18, United States Code, Section 981(a)(1)(C) and Title 28, United States

Code, Section 2461(c).

COREY F. ELLIS
UNITED STATES ATTORNEY
By: /s/ Emily Evans Limehouse
Emily Evans Limehouse (Fed. ID #12300)
Assistant United States Attorney
151 Meeting Street, Suite 200
Charleston, SC 29401
Tel.: (843) 727-4381
Fax: (843) 727-4443
Email: Emily.Limehouse@usdoj.gov

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