Information — United States v. Hammond (District of South Carolina, Entry Number 1)
Summary
An Information filed 05/25/22 as Entry Number 1 in United States of America v. Lori Hammond, a/k/a Lori McCracken, a/k/a Lori Blakely, Cr. No. 2:22-cr-454, in the U.S. District Court for the District of South Carolina, Charleston Division. The caption cites 18 U.S.C. § 2, § 371 and § 1343 and the forfeiture provisions 18 U.S.C. § 981(a)(1)(C) and 28 U.S.C. § 2461(c). The United States Attorney describes the PPP and EIDL programs and alleges that Hammond prepared PPP applications containing false employee and payroll information for entities and for coconspirators charged elsewhere. Count 1 charges conspiracy under 18 U.S.C. § 371 from in or around June 2020 to at least January 2021, and a forfeiture section lists seized bank funds, real property and a vehicle.
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“Information — United States v. Hammond (District of South Carolina, Entry Number 1).”
Original at ecf.scd.uscourts.gov. Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/court-filing-usa-v-hammond-dkt-1-59eb3298a5/
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2:22-cr-00454-DCN Date Filed 05/25/22 Entry Number 1 Page 1 of 16
IN THE DISTRICT COURT OF THE UNITED STATES
FOR THE DISTRICT OF SOUTH CAROLINA
CHARLESTON DIVISION
UNITED STATES OF AMERICA ) 2:22-cr-454
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)
LORI HAMMOND, a/k/a Lori ) 28 U.S.C. § 2461(c)
McCracken, a/k/a Lori Blakely )
) INFORMATION
THE UNITED STATES ATTORNEY CHARGES:
At times relevant to this Information:
The Defendant and Coconspirators
1. The Defendant, LORI HAMMOND, a/k/a Lori McCracken, a/k/a Lori Blakely,
(“LORI HAMMOND”) was a citizen of the United States and resident of South Carolina.
2. Catherine (“Cassie”) Needham (“Needham”), charged elsewhere, was a citizen of
the United States and resident of South Carolina.
3. Christopher Conrad (“Conrad”), charged elsewhere, was a citizen of the United
States and resident of South Carolina.
4. Jontrell Wright (“Wright”), charged elsewhere, 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-00454-DCN Date Filed 05/25/22 Entry Number 1 Page 2 of 16
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. Modern Muscle Racing Equipment LLC (“Modern Muscle”) is not a registered
business 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 Modern Muscle. In PPP loan documents, LORI HAMMOND claimed sole ownership
of Modern Muscle.
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16. Steady Moddin’ Motorsports LLC (“Steady Moddin”) is an LLC 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 Steady Moddin’. In PPP loan documents, LORI HAMMOND claimed sole
ownership of Steady Moddin’.
17. Coastal Cardiology Associates LLC (“Coastal Cardiology”) is not a registered
business 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 Coastal Cardiology. In PPP loan documents, Broadas Pace, Jr. claimed ownership over
Coastal Cardiology; however, Broadas Pace, Jr. died nearly nine months prior to the submission
of the PPP loan documents.
18. Port City Transport and Logistics LLC (“Port City”) was previously registered with
the South Carolina Secretary of State, but has gone through a series of name changes, including
changing its name to Steady Moddin’. According to documentation from the South Carolina
Department of Employment and Workforce, there are no employer accounts on file with the name
Port City. In PPP loan documents, LORI HAMMOND is listed as the sole principal of Port City.
19. Carolina Chrome and Plating LLC (“Carolina Chrome”) is not a registered business
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
Carolina Chrome. In PPP loan documents, LORI HAMMOND is listed as the sole principal of
Carolina Chrome.
20. Salon 813 LLC (“Salon 813”) is an LLC that is currently in good standing with the
South Carolina Secretary of State. According to documentation from the South Carolina
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Department of Employment and Workforce, there are no employer accounts on file with the name
Salon 813. In PPP loan documents, Needham claimed sole ownership of Salon 813.
21. Camiwear Apparel (“Camiwear”) is an LLC 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
Camiwear. In PPP loan documents, Needham claimed sole ownership of Camiwear.
22. Freedom Autoglass Supply 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 Freedom Autoglass Supply. In PPP loan documents, Needham claimed sole ownership
of Freedom Autoglass Supply.
23. Progression Transport 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
Progression Transport. In PPP loan documents, Conrad claimed sole ownership of Progression
Transport.
24. Velocity Motor Sports (“Velocity”) 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 Velocity. In PPP loan documents, Conrad claimed sole ownership of Velocity.
25. Port City Container Transport 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
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the name Port City Container Transport. In PPP loan documents, Conrad claimed sole ownership
of Port City Container Transport.
26. 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, Wright claimed sole
ownership of Wright & Sons.
Relevant Banks and Lenders
27. 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.
28. Fundbox Inc. (“Fundbox”) offers loans and lines of credit made by First Electronic
Bank, a federally insured banking institution. Fundbox also offers loans and lines of credit directly.
Fundbox is an approved lender for PPP loans, and as such, was authorized to lend funds to eligible
borrowers under the terms of the PPP.
29. Fountainhead Commercial Capital (“Fountainhead”) is a non-bank, commercial
lender. Fountainhead is an approved lender for PPP loans, and as such, was authorized to lend
funds to eligible borrowers under the terms of the PPP.
30. South Carolina Federal Credit Union (“SCFCU”) is a federally insured financial
institution located in North Charleston, South Carolina. SCFCU is an approved lender for PPP
loans, and as such, was authorized to lend funds to eligible borrowers under the terms of the PPP.
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Overview of the Scheme
31. From in or around June 2020 through a date unknown to the United States Attorney
but up to at least January 2021, LORI HAMMOND caused multiple 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, LORI
HAMMOND used the identity of a deceased individual, 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.
32. LORI HAMMOND assisted Needham, Conrad, and 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 LORI HAMMOND submitted on behalf of
Needham, Conrad, and Wright contained false and fraudulent information about the number of
employees and corresponding payroll expenses.
33. Based on the false and fraudulent representations and submissions in the PPP loan
applications and other supporting documentation submitted by LORI HAMMOND, Needham,
Conrad, and Wright, with LORI HAMMOND’s assistance and direction, the approved PPP
lenders funded the PPP loans.
34. After the PPP loan funds were deposited into the respective accounts, LORI
HAMMOND, Needham, Conrad, and Wright used the funds for non-qualifying, non-business-
related purposes, in violation of the terms of the PPP loan program.
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COUNT 1
Conspiracy to Commit Wire Fraud (18 U.S.C. § 371)
35. The allegations contained in paragraphs 1 through 34 are incorporated by reference
as if set forth fully herein.
36. From in or around June 2020 to and continuing until at least January 2021, in the
District of South Carolina and elsewhere, the defendant, LORI HAMMOND, 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, in that LORI
HAMMOND, and others known and unknown to the United States Attorney, did transmit and
caused to be transmitted by means of wire, radio, or television communication in interstate
commerce, writings, signs, signals, pictures and sounds for the purpose of executing the scheme
and artifice, in violation of Title 18, United States Code, Section 1343;
Object of the Conspiracy
37. The object of the conspiracy was for the defendant, LORI HAMMOND, to
provide false representations on PPP loan applications submitted to federally insured financial
institutions to obtain money and property. In the loan applications, LORI HAMMOND used the
identity of a deceased individual, 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
38. In furtherance of the conspiracy, the defendant, LORI HAMMOND, and others
known and unknown to the United States Attorney, including Needham, Conrad, and Wright,
committed the following overt acts in the District of South Carolina, by submitting the following
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loan applications on behalf of the businesses as set forth below:
Applicant Business Name Date of Loan Amount Lender
Funding
Hammond Modern Muscle July 20, $363,500.00 BankVista
Racing 2020
Hammond Steady Moddin’ July 20, $643,100.00 Bankvista
Motorsports 2020
Hammond, as Coastal Cardiology July 31, $534,200.00 BankVista
“Broadus Pace” Associates 2020
Hammond Port City Transport June 18, $299,132.50 Fundbox
and Logistics 2020
Hammond Carolina Chrome June 19, $410,900.00 Fountainhead
and Plating 2020
Needham Salon 813 LLC July 28, $433,000.00 BankVista
2020
Needham Camiwear Apparel July 24, $604,800.00 BankVista
2020
Needham Freedom Autoglass July 28, $206,400.00 BankVista
Supply 2020
Conrad Progression May 11, $33,600.00 SCFCU
Transport 2020
Conrad Velocity Motor July 21, $413,500.00 BankVista
Sports 2020
Conrad Port City Container July 28, $319,900.00 BankVista
Transport 2020
Wright Wright & Sons July 21, $433,000.00 BankVista
Transport 2020
39. LORI HAMMOND and the other members of the conspiracy fraudulently
obtained $4,721,638.50 in PPP loan funds.
All in violation of Title 18, United States Code, Sections 371 and 2.
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COUNT TWO
Wire Fraud (18 U.S.C. § 1343)
The Scheme to Defraud
40. The allegations contained in paragraphs 1 through 34, 38 and 39 of this Information
are incorporated herein by reference.
41. 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, LORI HAMMOND, 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
42. It was part of the scheme that LORI HAMMOND electronically submitted a PPP
loan application to CS, who in turn submitted the application to BankVista on July 5, 2020. In the
loan application, LORI HAMMOND requested a PPP loan for Modern Muscle. According to the
loan application, Modern Muscle is located at 4413 Dorchester Road, North Charleston, SC.
Modern Muscle claimed 18 employees with a monthly payroll of $145,421.00. LORI
HAMMOND is listed as 100% owner, signed as the authorized representative, and included a
photocopy of her driver’s license as required with the application.
43. In the loan application, LORI HAMMOND included material fraudulent and false
representations and submissions. Specifically, LORI HAMMOND fraudulently inflated the
number of employees and the corresponding payroll expenses. At the time of the submission,
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Modern Muscle was an inactive business. LORI HAMMOND submitted a false business address
for Modern Muscle and attached fraudulent tax documents to the loan application. BankVista
approved the loan application for Modern Muscle and submitted the loan application to the SBA
for funding.
44. On or about July 20, 2020, based on LORI HAMMOND’S fraudulent and false
representations and submissions, the U.S. Treasury or SBA approved the loan and distributed
approximately $363,500.00 in PPP loan funds to LORI HAMMOND’S personal bank account.
45. After LORI HAMMOND received the funds, she used the funds for non-
qualifying, non-business-related purposes, in violation of the terms of the PPP loan program,
including by purchasing a home and a vehicle, among other personal purchases.
All in violation of Title 18, United States Code, Section 1343.
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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, LORI HAMMOND, 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:
A. 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 her violation of 18 U.S.C. §§ 371
and 1343.
B. Bank Accounts:
(1) $24.59 in funds from BB&T Truist Bank account x7861 in the name
of Lori Hammond and Coastal Document Services
Seized From: Lori Hammond
Seizure Date: January 25, 2021
Asset ID: 21-FBI-002262
(2) $1,850.40 in funds from BB&T Truist Bank account x5638 in the name of
Lori Hammond and Coastal Document Services
Seized From: Lori Hammond
Seizure Date: January 25, 2021
Asset ID: 21-FBI-002261
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(3) $1,191.39 in funds from BB&T Truist Bank account x5611 in the name
of Lori Hammond dba High Voltage Retros
Seized From: Lori Hammond
Seizure Date: January 25, 2021
Asset ID: 21-FBI-002260
(4) $1,341,833.43 in funds from BB&T Truist Bank account x5603 in the
name of Lori Hammond
Seized From: Lori Hammond
Seizure Date: January 25, 2021
Asset ID: 21-FBI-002259
(5) $76.00 in funds from BB&T Truist Bank account x5581 in the name of
Lori Hammond
Seized From: Lori Hammond
Seizure Date: January 25, 2021
Asset ID: 21-FBI-002258
(6) $742.84 in funds from BB&T Truist Bank account x5573 in the name of
Lori Hammond
Seized From: Lori Hammond
Seizure Date: January 25, 2021
Asset ID: 21-FBI-002257
(7) $12,603.52 in funds from BB&T / Truist Bank account x5565 in the name
of Lori Hammond
Seized From: Lori Hammond
Seizure Date: January 25, 2021
Asset ID: 21-FBI-002256
(8) $414.58 in funds from BB&T / Truist Bank account x9125 in the name
of Lori Hammond
Seized From: Lori Hammond
Seizure Date: January 25, 2021
Asset ID: 21-FBI-002255
(9) $408.90 in funds from BB&T / Truist Bank account x2850 in the name of
Lori Hammond
Seized From: Lori Hammond
Seizure Date: January 25, 2021
Asset ID: 21-FBI-002254
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C. Real Property:
12 Plantation Drive
Manning, South Carolina 29102
Parcel ID: 162-00-01-034-00
Titled in the name of: Lori Hammond
Asset ID: 21-FBI-001801
D. Vehicle:
2020 Ford Mustang
VIN: 1FA6P8SJ1L5502622
Titled in the name of: Lori Denise Hammond
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;
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).
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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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