Guilty Plea Agreement — U.S. v. Shanna Niquia Hunt (E.D. Mo.)

Summary

A guilty plea agreement in United States of America v. Shanna Niquia Hunt, Case 1:25-cr-00046-SNLJ, in the United States District Court for the Eastern District of Missouri, filed October 9, 2025 as Doc. #: 27. The defendant agrees to plead guilty to the indictment, charging a false statement to a financial institution and wire fraud, and to pay $19,956.00 in restitution to the United States. The agreed facts state that the defendant applied for a PPP loan with Benworth Capital Partners, LLC using a fraudulent IRS Schedule C, and that Benworth deposited the proceeds into the defendant's bank account. The parties estimate a total offense level of 9, from a base offense level of 7, with 4 levels added for loss and two deducted for acceptance of responsibility. The agreement includes appeal and post-conviction waivers.

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

“Guilty Plea Agreement — U.S. v. Shanna Niquia Hunt (E.D. Mo.).” Original at ecf.moed.uscourts.gov. Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/court-filing-usa-v-hunt-dkt-27-e-d-mo-22e97eb0fa/, SHA-256 fb298c40a15eeb4bc936b56ba375e8e8683d892c7fe348c6fabab2564bc4a172.

Full text

Case: 1:25-cr-00046-SNLJ Doc. #: 27 Filed: 10/09/25 Page: 1 of 12 PageID #:
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UN ITED STATES DISTRICT COURT
EASTERN DISTRICT OF MISSO URI
SOUT HEASTERN DIVISION

UNITED STA TES OF AMERI CA, )
)
Pla intiff, )
) N O. 1:25 CR 46 SNLJ
V. )
)
SHANNA N IQ UIA H UNT, ) FILED
)
Defendant. ) OCT O9 2025
U. S. DISTRICT COURT
EASTERN DISTRICT OF MO
CAPE GIRARDEAU
GUILTY PLEA AGREEMENT

Come now the parti es and hereby agree, as follows:

1. PARTIES:

The parties are the defend ant Shanna N iquia Hunt, represented by defense co unsel Jaso n

A. Korn er, and th e United States of Ameri ca, (hereinafter "government"), represented by th e

Office of the United States Attorney fo r th e Eastern Di stri ct of Misso uri . Thi s agreement does

not, and is not intend ed to, bind any governm ental offi ce or agency other th an the United States

Attorney for the Eastern Di strict of Misso uri. The Court is neither a party to nor bound by th is

agree ment.

2. GUILTY PLEA:

Pursuant to Rul e 1l (c)( l )(A), Federal Rul es of Criminal Procedure, in exchange fo r

defendant's voluntary pl ea of guilty to the indictment, th e governm ent agrees th at no furth er

fed eral prosecution of the defendant w ill be brought in thi s Di stri ct relati ve to the und erly ing

facts supporting the charges in the indi ctm ent herein , of which th e gove rnm ent is aware at thi s

time. The defend ant al so agrees to pay $ 19,956 .00 in restituti on to th e United States of America
Case: 1:25-cr-00046-SNLJ Doc. #: 27 Filed: 10/09/25 Page: 2 of 12 PageID #:
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as a part of thi s plea.

Furthermore, th e parties agree that e ither party may requ est a sentence above or below the

U.S . Sentencing Guide li nes range (co mbinati on of Total Offense Level and Crim ina l H istory

Catego ry) ultimately determined by th e Co urt pursuant to any chapter of the Guidelines, Title 18

United States Code, Secti on 3553, or any other prov ision or rul e of law not addressed herei n. The

parti es furth er agree th at noti ce of any such requ est w i11 be given no later than ten ( 10) days prior

to se ntencing and that said noti ce sha ll spec ify th e legal and factual bases for the requ est.

3. ELEMENTS:

The crime of making a fa lse statement to a fin ancia l in stitution, as charged in Count I of

the Indi ctment, has three elements, which are: One, th e defend ant knowingly made false

statements, namely th at the defe nd ant was the owner of a qua lifying sma ll business, and th at PPP

loan proceeds wo uld be spent on permi ss ibl e expenses, to a finan cial instituti on; Two , the

defend ant made the fa lse statement fo r th e purpose of influencing th e action of the fin ancial

in stitution upon an applicati on for a PPP loan; and Three , that the financial in stitution was backed

by the Small Business Admini strati on at the tim e the statement was made.

The crim e of w ire fraud, as charged in Co unt II of the indictm ent, has fo ur elements, whi ch

are: One, the defend ant vo luntarily and intentionally parti cipated in a scheme to obtain money by

mean s of material fa lse representatio ns, namely th e submi ss ion of a fraudulent PPP Loan

applicati on, Two, th e defendant did so wi th the intent to defraud ; Three, the defendant used, or

caused to be used, an interstate w ire communi cati on, that is, use of an internet loan applicati on

portal, in furth eran ce of so me essent ia l step in the scheme; and Four, th e scheme affected a

financial instituti on.

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4. FACTS:

The parti es agree that the facts in this case are as fo llows and that the Government wo uld

prove these facts beyo nd a reasonabl e doubt if the case were to go to trial. These facts may be

considered as relevant conduct pursuant to Section 1B 1.3 :

The Coronav irus Aid , Relief, and Eco nomi c Security (" CARES ") Act is a federa l law

th at was enacted in or around Ma rch of 2020 to provide emergency fin ancial ass istance to the

millions of Ame ri cans suffering the eco nomic impact caused by the COVTD-1 9 pandemic. The

CARES Act authorized the Small Business Admini strati on (SBA) to iss ue forgivab le loans to

smalI businesses for job retenti on and certai n other expenses through the Paycheck Protection

Program ("PPP") .

To obtain a PPP loan, a quali fyi ng business was required to submit a PPP loan

app li cation , signed by an authorized representati ve of the bu siness who was req uired to certify

that, amo ng other things, the small business was in operation on February 15, 2020, and that

SBA loan proceeds will be used on ly for business-re lated purposes as spec ified in the loan

app li cation and consistent with the Paycheck Protection Program Rules, such as retaining

workers, maintaining payro ll , making mortgage interest payments, lease payments, and utility

payments. The program also required the submi ss ion of certain docum ents related to the identity

of the applicant and th e expenses of the bu si ness, like payro ll , that wo uld be covered by the

loans.

Shanna Hunt of Caruthersvi lle, Pemi scot County Misso uri was identified as a person who

had filed via an interactive internet portal, whi ch constitutes an interstate wire communication, a

fraudu lent application for a PPP loan with Benworth Cap ital Partners, LLC, of Coral Gab les

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Florid a. Benwo rth was an SBA approved fi nanc ia l instituti on fo r th e PPP Loan p rogram. Shann a

Hunt did not own o r operate an eli gib le business and had submitted a fraudul ent IRS Sched ul e C

to obta in th e loan. Shann a Hunt had also up loaded a copy of her photo and M isso uri driver' s li ce nse

to the we bsite to prove her ident ity. Shann a Hunt appli ed for a loa n on A pril 30, 202 1, and

Benworth depos ited th e proceeds, $ 19,956.00 into her bank acco unt on M ay 19, 202 1.

Agents co ndu cted a non-custod ial interv iew of Shann a Hunt and asked her about her

obtaining a PPP Loan. Hun t repli ed "l did it ... I' m not g unna lie to y'all .. .I regret it." H unt a lso

admitted th at th e info rm atio n on her IRS Schedul e C was fal se, and that she co uld not te lI age nts

one thing that she had spent the proceeds of the loan o n. Hunt al so said th at she " kind of figured"

gettin g a loan was aga in st the law.

As a part of th is pl ea the defendant admits th at she know ingly made fa lse statements to a

fin ancial instituti on fo r the pu rpose of obta ining a loan backed by the Small Busi ness

Admini strati on. She a lso ad mi ts that she vo luntarily and intentionall y parti cipated in a scheme to

obtain money, affecting a fin ancial insti tutio n, by means of making materi all y fa lse representations

via an interstate wire communi cation and th at she did so with the intent to defraud .

5. STATUTORY PENALTIES :

The defend ant und erstands that the max imum poss ible penalty as to each Co unt here in is

not more th an 30 years of imprisonment, a fi ne of not more than $ 1,000 ,000, or both a fi ne and

impriso nm ent and a term of supervised re lease of not more th an fi ve years.

ln the event defend ant is subj ect to any undischarged or anticipated term of imprison ment

imposed by any co urt, defendant has been appri sed by co unse l th at th e sentence imposed in this

case may be imposed consecut ive ly to the undi scharged or anti cipated term of imprisonment.

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6. U.S. SENTENCING GUIDELINES: 2023 MANUAL:

The defend ant understands that thi s offense is affected by the U.S. Sentencing Guidel ines

and the actual sentenc ing range is determined by both the Total Offense Level and the Criminal

History Category. The parti es agree that the fo llowin g are the U.S. Sentencing Guidelines Total

Offense Level provi sions th at app ly.

(1) Chapter 2 Offense Conduct:

(a) Base Offense Level: The parties agree that the base offense leve l is 7 as fo und

in Section 2Bl.l(a)( l) .

(b) Specific Offense Characteristics: The parti es agree that th e fo llowing

Spec ific Offense Characteristics ap ply: 4 leve ls should be added pursuant to Secti on

281.1 (b )(1 )(C) becaus e the loss exceeded $ 15,000 .00 .

(2) Chapter 3 Adjustments:

(a) Acceptance of Responsibility: The parties recommend that two levels should

be ded ucted pursuant to Sentenc ing Guidelines Secti on 3E l. l (a) because Defendant has clearly

demonstrated acceptance of responsibility .

The parti es agree th at if Defendant does not abide by a ll of th e agreements made with in

thi s document, Defendant's fai lure to comp ly is gro unds for th e loss of acceptance of

responsibility pursuant to Sentenc ing Guidelines Secti on 3El. 1. The parti es furth er agree that

Defendant's e ligibility for a reduction pursuant to Sentencing Guide Iines Section 3E 1.1 is based

upon th e information known at the present tim e and that any actions of Defendant which occur or

which become known to the United States subsequ ent to this agreement and are inconsistent w ith

Defendant's acceptance of responsibi Iity including, but not Iim ited to criminal conduct, are

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gro unds for th e loss of acceptance of responsibi I ity pursuant to Sentencing Guidelines Section

3E l .1. In any even t, th e parties agree that a ll of th e remaining prov isions of thi s agreement

remain va lid and in full force and effect.

(b) Other Adjustments: T he parties reco mmend that no additiona l adjustments app ly.

(d) Crim inal History: The determination of the defend ant's Criminal Hi story Catego ry

shall be left to th e Co urt. E ither party may chall enge, befo re and at sentencing, the finding of the

Presentence Repo rt as to the defendant's criminal hi sto ry and th e app licab le category. T he

defendant's crimin al hi story is known to the defe ndant and is substantially avai lable in the

Pretrial Services Repo rt.

(e) Effect of Parties' U.S. Sentencing G uidelines Analys is : T he parties agree that the

Co urt is not bound by th e Gu idelines ana lys is agreed to here in . T he parti es may not have

foreseen a ll applicable Guidelines. The Co urt may, in its discreti on, app ly or not appl y any

Guid eline despite the agreement herein and the patii es shall not be perm itted to w ithd raw from

the plea agreement.

7. W AIYER OF APPEAL AND POST-CONVICTION RIGHTS:

a. Appeal: The defend ant has been fu lly apprised by defe nse counse l of th e defendant's

rights concern ing appeal and fully understands th e ri ght to appeal th e sentence under T itle 18,

United States Code, Secti on 3742.

(1) Non-Sentencing Issues: The parties waive a ll ri ghts to appea l all non -juri sdictional,

non-sentencing issues, including, but not limited to, any iss ues relating to pretri a l motions,

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di scovery and th e gui lty plea, the constitut iona lity of th e statute(s) to whi ch th e defend ant is

pleading guilty and whether defendant's co ndu ct fa ll s w ithin the sco pe of th e statute(s)

(2) Sentencing Issues : In the event the Co urt accepts the plea, accepts the U.S.

Sentencing Guid e lines Tota l Offense Level agreed to herein, and, after determining a Sentenc ing

Guid elines range, sentences the defend ant w ithin or below that range, th en, as part of this

agreement, th e defendant hereby wa ives all rights to appeal all se ntencing issues other than

Criminal Hi story, but only if it affects th e Base Offe nse Level or Crimin a l Hi story Category.

Simi larly, the Government hereby waives all rights to appeal all sentencing issues other than

Crimin al Hi story, prov ided the Co urt accepts th e plea, adopts the agreed Tota l Offense Level and

sentences the defend ant w ith in or above that range.

b. Habeas Corpus : The defend ant agrees to wa ive a ll ri ghts to co ntest th e conviction or

sentence in any post- conviction proceeding, including one pursuant to T itle 28, United States

Code, Sect ion 2255 , except fo r claim s of prosecutori a l mi sco ndu ct or ineffecti ve ass istance of

co unse l.

c. Right to Record s: The defendant wa ives all ri ghts, whether asserted d irectl y or by a

represe ntative, to requ est from any department or agency of the United States, any records

perta ining to th e investi gatio n and prosec ution of thi s case, including any records that may be

so ught un der the Freedom of informat ion Act, T itle 5, United States Code, Section 522, or the

Privacy Act, Title 5, Uni ted States Code, Secti on 552(a).

8. OTHER:

a. Disclosures Required by the United States Probation Office: The defendant agrees

to truthfu lly complete and sign fo rms as required by the United States Probati on Office prior to

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se ntencing and co nse nts to the release of these forms and any supporting docum entation by the

United States Pro bati on Offi ce to th e governm ent.

b. Civil or Administrative Action s not Barred; Effect on Other Governmental
Agencies:

Nothin g co ntained here in limi ts the rights and authority of the United States to take any

c ivil , tax, immi gration/deportati on or admini strati ve acti on against th e defend ant.

c. Supervised Release: Pursuant to any supervised re lease term , th e Co urt w ill impose

standard conditions upon th e defend ant and may impose special conditi ons re lated to the crime

the defend ant co mmitted. T hese condit ions w ill be restri cti o ns o n the defe nd ant to whi ch th e

defendant w ill be required to adhere. Vio lation of th e co nditions of supervised re lease res ul ti ng

in revocati on may require the defend ant to serve a term of impriso nment equ a l to the length of

th e term of superv ised release, but not greater th an th e term set forth in T itl e 18, United States

Code, Secti on 35 83(e)(3), w ithout credit fo r the tim e served after re lease. T he defendant

understands th at paro le has been abo li shed.

d. Mandatory Special Assessment: Pursuant to T itle 18, United States Code, Section

301 3, the Co urt is required to impose a mand atory spec ial assess ment of $ 100 per co unt fo r a

total of $200, whi ch th e defend ant agrees to pay at the tim e of sentenc ing. M oney pa id by the

defendant towa rd any restitut ion or fin e imposed by th e Co urt shall be first used to pay any

unpaid mand atory spec ia l assessment.

e. Possibility of Detention: T he defe nd ant may be subj ect to immedi ate detenti o n

pursuant to the prov isions of T itle 18, United States Code, Secti on 3 143.

f. Fines, Restitution and Costs of Incarceration and Supervision: The Co urt may

impose a fin e, costs of incarcerati on and cos ts of superv ision. The defendant agrees that any fi ne

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imposed by the Co urt w ill be due and payable immediate ly. The defendant agrees to pay

$19,956.00 in restituti on to the United States of A merica.

g. Forfeiture: T he defendant knowing ly and vo lun tari ly waives any right, tit le, and interest

in all items seized by law enforcement offic ials during the co urse of th e ir invest igation , whether

or not they are subj ect to forfeiture , and agrees not to co ntest the vesting of title of such items in

the U nited States. The defendant agrees to aba ndon [his/her] interest in all se ized items and further

agrees that said items may be disposed of or destroyed by law enforcement officials in any manner

w ithout furth er notice. By abandoning these items, the defend ant wa ives any future rights to

rece ive additiona l notice, a va luation of the items, or the opportunity to submit a claim to contest

the disposition or destructi on of the items that may exist und er any poli c ies or procedures of the

se izi ng agency(ies ).

9. ACKNOWLEDGMENT AND W AIYER OF THE DEFENDANT'S RIGHTS :

In pleading guilty, the defendant acknowledges, fu ll y understands and hereby waives his

rights, including but not limited to: the right to pl ead not guilty to the charges; the right to be

tried by a jury in a pub li c and speedy trial; the right to fi le pretrial motions, including motions to

suppress or exc lude ev idence; the right at such tria l to a pres umption of innocence; the right to

req uire the governm ent to prove the elements of the offenses charged against the defendant

beyond a reasonab le doubt; the right not to testify; the right not to present any ev idence; the right

to be protected from compelled se lf-incriminat ion; the right at tria l to co nfront and cross-

examine adverse witnesses; the right to testify and present ev idence and the right to compel the

attendance of witnesses. The defendant further und erstands that by thi s g uilty plea, the

defendant express ly wa ives all the rights set fo rth in thi s paragraph.

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The defendant full y und erstands that th e defend ant has the ri ght to be represented by

co un sel, and if necessary, to have th e Co urt appo int co un se l at tri al and at every other stage of

th e proceedin g. The defe nd ant's co un sel has expl ained th ese ri ghts and th e co nsequ ences of th e

wa iver of th ese ri ghts. The defend ant full y und erstands th at, as a res ult of th e guilty pl ea, no tria l

w ill , in fact, occ ur and that the onl y acti on rema ining to be taken in thi s case is th e imposition of

the sentence.

The defendant is full y sati sfi ed w ith th e represe ntation rece ived from defense co un sel.

The defendant has rev iewed the governm ent's ev idence and di scussed the governm ent's case and

alI poss ib le defe nses and defense w itnesses w ith defe nse coun sel. Defe nse coun se l has

co mp lete ly and sati sfactoril y expl ored a ll areas which the defendant has requested relative to th e

gove rnm ent's case and any defenses.

The term s and conditi ons co ntained in thi s stipu lation constitute the only plea offer whi ch

has bee n tend ered to th e defend ant by the Gove rnment here in . Defend ant has full y di scussed the

terms and conditi ons of th e offer w ith co un sel and the defendant understands and agrees to the

same.

10. VOLUNTARY NATURE OF THE GUILTY PLEA AND PLEA AGREEMENT:

Thi s doc um ent co nstitutes th e entire ag ree ment between the defendant and th e

government, and no other pro mises or inducements have been made, directl y or indirectl y, by

any age nt of the governm ent, including any Department of Ju stice attorn ey, co ncerning any plea

to be entered in this case. In additi on, th e defendant states that no person has, directly or

indirectly, threatened or coerced the defend ant to do or refrain from do ing anything in

connection w ith any aspect of thi s case, including entering a plea of guilty.
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The defend ant ackn owledges hav ing vo luntaril y entered into both th e pl ea agreement and

the guilty pl ea. The defend ant furth er acknowledges that thi s guilty pl ea is made of the

defe ndant's own free will an d th at th e defend ant is, in fact, guilty.

11. CONSEQUENCES OF POST-PLEA MISCONDUCT :

After pl eadin g guilty and befo re sentencing, if defendant commits any crim e, other th an

minor traffi c offenses, vi olates any conditions of re lease that results in revocati on, v iolates any

term of thi s guilty-pl ea agreement, intenti onall y prov ides mi sleadin g, inco mplete or untruthful

info rm at io n to th e U.S. P ro bati on Offi ce or fa il s to appear for sentencing, th e United States, at its

opti on may be re leased from its obli gations under thi s agreement. T he Gove rnment may a lso, in

its di screti on, proceed with th is agreement and may advocate for any sentencing pos ition

supported by the facts, inc lud ing but not limited to obstru cti on of justi ce and deni al of

acceptance of responsibility.

12. NO RIGHT TO WITHDRAW GUILTY PLEA:

Pu rsuant to Rul e l l (c) and (d), Federal Rul es of Crimin a l Procedure, the defendant

understands th at there wi II be no ri ght to w ithdraw the plea entered und er this agreement, except

w here the Co urt rej ects those porti ons of the plea agreement which deal w ith charges the

governm ent agrees to di smi ss or not to bring.

Tim . Willi s,
Ass istant U nited States Attorney
555 Independence Street, Suite 3000
Cape G irardeau, Mi sso uri 63 703

11
J , r •
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~ru
Shanna N iqui a Hunt
Defe ndant

I o/c;/JC~~
Date n A. Korn er
e Law Offi ce of Jason A. Ko rn er
79 11 Forsyth Boul evard, Suite 300
Clayton, MO 63 105

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