Complaint — United States v. John Michael Felts (Western District of Missouri, Document 1)
Summary
A Complaint by the United States in the Western District of Missouri, Southern Division, against John Michael Felts, Jennifer Marie Obert f/k/a Jennifer Marie Felts, WR Brewery Holdings, LLC, and White River Brewery, LLC, under the Federal Debt Collection Procedures Act and the Missouri Uniform Fraudulent Transfer Act. It alleges that Felts pleaded guilty on July 28, 2023, to conspiracy to commit wire fraud and wire fraud, was sentenced on December 17, 2024, to 24 months' imprisonment, and owes restitution of $8,173,736.00 to the Small Business Administration. It alleges that, with nothing of value in exchange, a warranty deed dated March 20, 2024, and an assignment dated May 24, 2024, moved the Commercial Street Property and WR Brewery Holdings, LLC. The United States seeks voidance of the transfers, a declaration of its lien, a money judgment against Obert, and an injunction.
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“Complaint — United States v. John Michael Felts (Western District of Missouri, Document 1).”
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IN THE UNITED STATES DISTRICT COURT FOR THE
WESTERN DISTRICT OF MISSOURI
SOUTHERN DIVISION
UNITED STATES OF AMERICA,
Plaintiff,
v.
JOHN MICHAEL FELTS, Civil No. 25-3252
JENNIFER MARIE OBERT f/k/a
JENNIFER MARIE FELTS,
WR BREWERY HOLDINGS, LLC, and
WHITE RIVER BREWERY, LLC,
Defendants.
COMPLAINT
The United States of America, by and through United States Attorney for the Western
District of Missouri R. Matthew Price, and the undersigned Assistant United States Attorney,
alleges upon information and belief as follows:
INTRODUCTION
1. This is a civil action initiated by the United States of America pursuant to the
Federal Debt Collection Procedures Act (“FDCPA”), 28 U.S.C. § 3001, et seq., and the Missouri
Uniform Fraudulent Transfer Act (“UFTA”), Mo. Rev. Stat. § 428.024, and involving fraudulent
transfers as to a debt owed to the United States.
JURISDICTION AND VENUE
2. Jurisdiction over this action is conferred by 28 U.S.C. §§ 1331, 1345, and 3001.
Case 6:25-cv-03252-JAM Document 1 Filed 09/04/25 Page 1 of 9
3. Venue is proper in this district under 28 U.S.C. § 1391 because the events giving
rise to this claim occurred within this district, and under 28 U.S.C. § 3004(b), as this is an action
to enforce a debt to the United States.
THE PARTIES
4. Plaintiff is the United States of America proceeding in its sovereign capacity under
28 U.S.C. § 1345 and 18 U.S.C. § 3664(m)(1)(A)(ii).
5. Defendant John Michael Felts (“Debtor”) is a natural person. He is currently in the
custody of the United States Bureau of Prisons and can be served at Forrest City Low FCI, Forrest
City, Arkansas.
6. Defendant Jennifer Marie Obert f/k/a Jennifer Marie Felts is a natural person and
can be served at 926 East Greenwood, Springfield, Missouri 65807.
7. Defendant WR Brewery Holdings, LLC is a limited liability company organized
under Chapter 347 of the Missouri Revised Statutes, and can be served through its registered agent,
Jennifer Marie Obert at the previously referenced address, or through the Missouri Secretary of
State.
8. Defendant White River Brewing, LLC is a limited liability company organized
under Chapter 347 of the Missouri Revised Statutes, and can be served through its registered agent,
Ross Chaffin, at 1605 East Sunshine, Springfield, Missouri 65804, or through the Missouri
Secretary of State.
STATEMENT OF FACTS
9. On or about April 28, 2020, Debtor organized WR Brewery Holdings, LLC
pursuant to Chapter 347 of the Revised Statutes of Missouri. [Exhibit A.]
Case 6:25-cv-03252-JAM Document 1 Filed 09/04/25 Page 2 of 9
10. On or before March 1, 2021, WR Brewery Holdings, LLC, acquired property at 505
West Commercial Street, Springfield, Greene County, Missouri, which is more particularly
described as follows (herein “Commercial Street Property”):
Beginning at the Northeast corner of Lot Two (2), Block Thirty-
three (33), ORIGINAL PLAT OF NORTH SPRINGFIELD, in the
City of SPRINGFIELD, GREENE County, Missouri, according to
the recorded plat thereof; thence South along the West right of way
line of Lyon Avenue, 149.54 feet to the intersection of the West right
of way line of said Lyon Avenue and the North line of Commercial
Street; thence Westerly along the North right of way line of
Commercial Street, a distance of 159.46 feet to the line that divides
the East Half (E½) of the Southeast Quarter (SE¼) of Section Eleven
(11), Township Twenty-nine (29) North, Range Twenty-two (22)
West, into East and West halves; said point being 254.14 feet South
of the centerline of the Burlington-Northern Railroad; thence North
along the line that divides said East Half (E½) of the Southeast
Quarter (SE¼) of Section Eleven (11), Township Twenty-nine (29)
North, Range Twenty-two (22) West into East and West halves, a
distance of 154.53 feet to the North line of Lot Two (2), Block
Thirty-tree (33) of the ORIGINAL TOWN OF NORTH
SPRINGFIELD, as projected West; thence East along the North line
of said Lot Two (2), a distance of 157.50 feet to the point of
beginning, in the City of SPRINGFIELD, GREENE County,
Missouri.
A true and correct copy of the deed is attached hereto as Exhibit B.
11. The Commercial Street Property has done business as White River Brewing since
approximately 2012. Since 2021, the Debtor has held himself out publicly as the owner and
operator of White River Brewing and has benefitted financially from that ownership. Geoff Pickle,
White River Owner Plans Satellite Location on South Side, Springfield Business Journal (Nov. 16,
2021), https://sbj.net/stories/white-river-owner-plans-satellite-location-on-south-side,76937.
12. Since being purchased by the Debtor in 2021 and until the Debtor was convicted of
a felony, it operated as a fully functional brewery and tap room, open to the public, and contains
numerous items, both known and unknown, of personal property within the premises, as well as
Case 6:25-cv-03252-JAM Document 1 Filed 09/04/25 Page 3 of 9
property associated with that business, including, brewing and distribution equipment, tables,
chairs, inventory, ingredients used in brewing, and other unknown items.
13. Further, the business has intellectual property associated with it, including brand
names, product names, logos, and trade secrets.
14. In the case styled United States v. John Michael Felts, Case No. 23-03077-01-CR-
S-SRB (W.D. Mo.), Debtor waived indictment and pleaded guilty to conspiracy to commit wire
fraud and wire fraud, pursuant to an agreement with the Government on July 28, 2023. [See
Information and Plea Agreement, Docs. 4, 8, United States v. Felts, Case No. 23-03077-01-CR-S-
SRB.]
15. The felony charges arose from Debtor’s conduct between January 2018 and
September 13, 2022, in which he owned several limited liability companies and used those
companies to apply for fraudulent relief through the Coronavirus Aid, Relief, and Economic
Security (“CARES”) Act, including monetary relief through the Paycheck Protection Program and
Economic Injury Disaster Loans.
16. As part of Debtor’s plea agreement with the Government, Debtor agreed that he
would be liable to pay “at least $9,988,817” in restitution for his illegal conduct and that agreed
restitution would be ordered pursuant to 18 U.S.C. § 3663A, the Mandatory Victims Restitution
Act (“MVRA”). [Plea Agreement, Doc. 8, ¶ 16a.]
17. Further, Debtor agreed that he “has made no transfer of assets or property for the
purpose of: (1) evading financial obligations created by this Agreement; (2) evading obligations
that may be imposed by the Court; or (3) hindering efforts of the USAO to enforce such financial
obligations. Moreover, the [Debtor] promises that he will make no such transfers in the future.”
[Plea Agreement, Doc. 8, ¶ 16j.]
Case 6:25-cv-03252-JAM Document 1 Filed 09/04/25 Page 4 of 9
18. On March 20, 2024, Jennifer Felts formed defendant White River Brewery, LLC,
pursuant to an Articles of Organization filed with the Missouri Secretary of State. [Exhibit C.]
19. On or about March 20, 2024, WR Brewery Holdings, LLC executed a warranty
deed, signed by Debtor acting in his capacity as the sole member of WR Brewery Holdings, LLC,
in favor of White River Brewery, LLC for the Commercial Street Property. A true and correct copy
of this deed is attached hereto as Exhibit D.
20. Neither Debtor nor WR Brewery Holdings, LLC received anything of value in
exchange for the conveyance of the Commercial Street Property.
21. As the sole member of WR Brewery Holdings, LLC, and due to Debtor’s
aforementioned felony conviction, the Missouri Division of Alcohol and Tobacco Control of the
Department of Public Safety revoked WR Brewery Holdings, LLC’s license to serve alcohol on
May 2, 2024. [Exhibit E.]
22. Prior to Debtor’s criminal sentencing, on May 24, 2024, Debtor executed an
assignment, transferring “one hundred percent (100%) cumulative membership interest in WR
Brewery Holdings, LLC,” to Jennifer Marie Felts. [Exhibit F.] Debtor received nothing of value in
exchange for his conveyance of WR Brewery Holdings, LLC.
23. Debtor was sentenced on December 17, 2024, and ordered to serve 24 months’
imprisonment and pay restitution in the amount of $8,173,736.00 to the Small Business
Administration, along with a $200.00 special assessment. The restitution and special assessment
were made due and payable immediately. [See Judgment and Commitment, Doc. 38, United States
v. Felts, Case No. 23-03077-01-CR-S-SRB (W.D. Mo.).]
24. On March 7, 2025, a judgment of uncontested dissolution was entered in the Circuit
Court of Christian County, Missouri, dissolving the marriage of Debtor and Jennifer Marie Obert
Case 6:25-cv-03252-JAM Document 1 Filed 09/04/25 Page 5 of 9
and dividing the marital estate of the two, with the Court awarding each party their own personal
belongings, debts, and retirement accounts.
25. As part of the marital settlement and separation agreement, Debtor consented to the
award of the entirety of “WR Brewery Holdings, a/k/a White River Brewing Company, and all
property of the business, including real property described […] [Debtor] waives any and all interest
in WR Brewery Holdings, a/k/a White River Brewing Company.” Further, Jennifer Marie Obert
“acknowledges and assumes the risk that the federal government may attempt to designate the
[White River Brewing] property for seizure or forfeiture in the future as part of restitution or other
proceedings.” [Exhibit G.]
26. As of filing, Debtor owes $8,173,736.00 to the United States in restitution.
27. The Court’s judgment in Debtor’s criminal case constitutes a lien in favor of the
United States on all property and rights belonging to the Debtor. 18 U.S.C. § 3613(c).
CLAIMS FOR RELIEF
FIRST CLAIM FOR RELIEF
28 U.S.C. §§ 3304(b)(1)(A) and 3306(a)(1)
(Avoidance of Fraudulent Conveyances)
28. The allegations of paragraphs 1 through 27 are incorporated herein.
29. Debtor owes a debt to the United States as the FDCPA defines such term.
30. The transfer of the transfer of the Commercial Street Property from WR Brewery
Holdings, LLC to White River Brewery, LLC by warranty deed was made with the actual intent to
hinder, delay, or defraud the United States.
31. Based on the foregoing, the transfer of the Commercial Street Property was
fraudulent as to a debt of the United States.
Case 6:25-cv-03252-JAM Document 1 Filed 09/04/25 Page 6 of 9
SECOND CLAIM FOR RELIEF
28 U.S.C. §§ 3304(b)(1)(B) and 3306(a)(1)
(Avoidance of Fraudulent Conveyances)
32. The allegations of paragraphs 1 through 27 are incorporated herein.
33. The transfer of the Commercial Street Property from WR Brewery Holdings, LLC
to White River Brewery, LLC by warranty deed was made without receiving of reasonably
equivalent value in exchange for the transfer, and Debtor believed or reasonably should have
believed that he would incur debts beyond his ability to pay as they became due.
34. Based on the foregoing, the transfer of the Commercial Street Property was
fraudulent as to a debt of the United States.
THIRD CLAIM FOR RELIEF
Mo. Rev. Stat. § 428.024
(Avoidance of Fraudulent Conveyances)
35. The allegations of paragraphs 1 through 27 are incorporated herein.
36. The transfer of the Commercial Street Property from WR Brewery Holdings, LLC
to White River Brewery, LLC by warranty deed was made with the actual intent to hinder, delay,
or defraud the United States.
37. Based on the foregoing, the transfer of the Commercial Street Property was
fraudulent as to a debt of the United States.
FOURTH CLAIM FOR RELIEF
Mo. Rev. Stat. § 428.024
(Avoidance of Fraudulent Conveyances)
38. The allegations of paragraphs 1 through 27 are incorporated herein.
39. The transfer of the Commercial Street Property from WR Brewery Holdings, LLC
to White River Brewery, LLC by warranty deed made without receiving of reasonably equivalent
value in exchange for the transfer, and Debtor believed or reasonably should have believed that he
Case 6:25-cv-03252-JAM Document 1 Filed 09/04/25 Page 7 of 9
would incur debts beyond his ability to pay as they became due.
40. Based on the foregoing, the transfer of the Commercial Street Property was
fraudulent as to a debt of the United States.
FIFTH CLAIM FOR RELIEF
28 U.S.C. § 3306(a)(3)
(Money Judgment)
41. The allegations of paragraphs 1 through 27 are incorporated herein.
42. The United States is entitled under the FDCPA to a money judgment against
Defendant Jennifer Marie Obert in an amount that reflects Debtor’s equity interest in the
Commercial Street Property and WR Brewery Holdings, LLC but not to exceed the amount that
Debtor owes on his restitution judgment.
SIXTH CLAIM FOR RELIEF
28 U.S.C. § 3306(a)(3)
(Injunctive Relief)
43. The allegations of paragraphs 1 through 27 are incorporated herein.
44. The United States is entitled under the FDCPA to an injunction against Defendant
Jennifer Marie Obert and Debtor to prevent disposition, transfer, alteration of title to, diminution
of the value of equity in, mortgage, refinance, or encumbrance of the Commercial Street Property
and WR Brewery Holdings, LLC.
PRAYER FOR RELIEF
WHEREFORE, the UNITED STATES requests relief as follows:
45. A declaration of nullity and voidance of Debtor’s transfer of the Commercial Street
Property and WR Brewery Holdings, LLC to Defendant Jennifer Marie Obert;
46. A declaration that the United States’ Lien applies to the Commercial Street Property
and WR Brewery Holdings, LLC;
Case 6:25-cv-03252-JAM Document 1 Filed 09/04/25 Page 8 of 9
47. A money judgment against Defendant Jennifer Marie Obert in an amount that
reflects Debtor’s actual equity interest in the Commercial Street Property and WR Brewery
Holdings, LLC but not to exceed the amount that Debtor owes on his restitution judgment;
48. An injunction precluding either Defendant Jennifer Marie Obert or Debtor from
disposing of, transferring, altering title to, mortgaging, refinancing, diminishing the value of equity
in, or encumbering the Commercial Street Property and WR Brewery Holdings, LLC;
49. An award of costs of these proceedings; and
50. Any other relief as the Court deems just and reasonable, and as the circumstances
may require.
Respectfully submitted,
R. MATTHEW PRICE
United States Attorney
/s/ Anthony M. Brown
ANTHONY M. BROWN
Assistant United States Attorney
Missouri Bar No. 62504
901 East St. Louis Street
Suite 500
Springfield, Missouri 65806
(417) 575-8167
E-mail: Anthony.Brown2@usdoj.gov
Case 6:25-cv-03252-JAM Document 1 Filed 09/04/25 Page 9 of 9
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