Guilty Plea Agreement — U.S. v. Victoria Natasha Hunt (E.D. Mo.)

Summary

A guilty plea agreement in United States of America v. Victoria Natasha Hunt, Case 1:25-cr-00045-SNLJ, in the United States District Court for the Eastern District of Missouri, filed September 17, 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 $19,870.00 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 Schedule C for a business that did not exist, 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. Victoria Natasha 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-7f880f6c09/, SHA-256 43548ec57632eefc40c00ec74bb29eb70e40d34dadac9fc2b439e2e56f973b59.

Full text

Case: 1:25-cr-00045-SNLJ Doc. #: 27 Filed: 09/17/25 Page: 1 of 12 PageID #:
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UN ITE D STATES DISTRICT COURT
EASTERN DJ STRI CT OF MISSO URI
SOUTHEASTERN DIVISION
FILED
UN ITED ST ATES OF AMERICA, )
) SEP 17 2025
Plaintiff, )
U. S. DISTRICT COURT
) NO . I :25 CR 45 SNLJ EASTERN DISTRICT OF MO
V. ) CAPE GIRARDEAU
)
VICTORIA NA TAS HA HUNT, )
)
Defend ant. )
)

GUILTY PLEA AGREEMENT

Come now th e parti es and hereby ag ree, as foll ows:

I . PARTIES:

The parti es are the defendant V ictori a Hunt, represented by defen se co unse l Philip

E isenhauer, and the United States of Ame ri ca, (hereinafter "governm ent"), represented by th e

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

not, and is not intended to, bind any governm ental offi ce or agency other than th e United States

Attorney for th e Eastern Di stri ct of Misso uri. The Court is neither a party to nor bound by this

agreement.

2. GUILTY PLEA:

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

defendant' s vo luntary pl ea of guilty to th e indictm ent, th e governm ent agrees th at no furth er

fed eral prosecution of the defendant will be brought in thi s Di stri ct relati ve to th e und erlying

facts supportin g the charges in the indi ctment herein , of which th e gove rnment is aware at thi s

time. The defend ant al so agrees to pay $19,870 .00 in restitution to the U nited States of America
Case: 1:25-cr-00045-SNLJ Doc. #: 27 Filed: 09/17/25 Page: 2 of 12 PageID #:
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as a part of thi s pl ea.

Furth erm ore, th e parties agree th at either party may requ est a sentence above or below th e

U.S. Sentencing Guid elines range (combin ation of Total Offense Leve l and Crimin al History

Category) ultim ately determin ed by the Co urt pursuant to any chapter of th e Guidelines, T itle 18

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

parties furth er agree that noti ce of any such request w i11 be g ive n no later than ten (10) days prior to

sentencing and that said notice shall spec ify th e legal and factual bases for th e request.

3. ELEMENTS:

The crime of mak ing a fa lse statement to a fin ancia l institut ion, as charged in Co unt I of

the Indictm ent, has three elements, w hi ch are: One, th e defend ant kn owing ly made fa lse

statements, name ly th at the defend ant was the owner of a qualify ing sma lI bu s iness, and that PPP

loan proceeds wo uld be spent o n permi ss ibl e expenses, to a finan c ial institution; Two, the

defendant made th e fa lse statement for th e purpose of influ enc ing th e acti o n of the fin ancial

instituti on upon an application fo r a PPP loan; and Three, that the loan was bac ked by the Small

Business Admini strati on at the time the statement was made.

The crim e of wire fraud, as charged in Co unt Il of th e indictm ent, has fo ur e lements, w hi ch

are: One, th e defend ant vo luntaril y and intenti ona ll y parti c ipated in a scheme to obtain money by

means of materi al fal se representatio ns, namely th e submi ss ion of a fraudul ent PPP Loan

application , Two , th e defend ant did so w ith the intent to defraud ; Three, th e defendant used, or

caused to be used, an interstate w ire co mmuni cati on, that is, use of an internet loan appli cation

portal , in furth erance of so me essenti a l step in the sc heme; and Four, th e scheme affected a

fin ancial instituti on.

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4. FACTS:

The parties agree th at th e facts in th is case are as fol lows and that th e Gove rnment wo uld

prove these fa cts beyo nd a reaso nable doubt if th e case were to go to tri a l. T hese facts may be

co ns idered as relevant co nduct pu rsuant to Secti on l B 1.3:

T he Coro nav irus Aid , Re lief, an d Eco nomi c Security ("CARES") Act is a federal law

th at was enacted in or around March of 2020 to prov ide emergency fin anc ial ass ista nce to th e

milli ons of Ameri cans suffe rin g th e eco nomi c impact caused by th e COVTD- 19 pand emi c. The

CARES Act auth ori zed the Small Bu siness Administrati on (SBA) to iss ue fo rg ivable loans to

sma lI businesses for j ob retention and certa in other expenses th ro ugh th e Paycheck Protection

Program (" PPP ").

To obta in a PPP loa n, a qua li fy ing bus iness was required to submit a PPP loan

appli cation, s ig ned by an authorized representati ve of th e bu s iness who was required to certify

th at, among other thin gs, the sma ll busi ness was in operati on on Fe bruary 15, 2020, and that

SBA loan proceeds w ill be used onl y for business- related purposes as spec ifi ed in the loan

appli cati on and co ns istent w ith the Payc heck Protecti on Program Rul es, such as reta ining

wo rkers, ma inta ining payro ll , making mortgage interest payments, lease payments, and utili ty

pay ments. The program a lso req uired th e submi ss ion of certain doc um ents re lated to th e identi ty

of the appli cant and th e expenses of the bus iness, like payro ll , th at wo uld be covered by the

loa ns.

Victoria Hunt of Caruthersv ill e, Pemi scot Co unty Missouri was identifi ed as a

person who had fil ed vi a an interacti ve intern et po rtal, w hich constitutes an interstate w ire

co mmunicati on, a fraudul ent applicati on for a PPP loan w ith Benwo rth Capita l Partn ers, LLC

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(Benworth), a financ ia l institution headquartered in Cora l Gabl es, F lorida. Benworth was an

SBA approved financial instituti on for the PPP Loan program. Public records and in vestigation

showed th at Hunt did not own or operate an eligible busi ness and had submitted a fraudu lent

Sched ule C falsely stating gross income and expenses for a business th at did not exist. Hunt had

also upl oaded a copy of her photo and Misso uri driver's license to th e webs ite to prove her

identity. Hunt applied for a loan on Apr il 30, 202 1, and Benworth deposited the proceeds,

$ 19,870.00 into her bank account on June 1, 202 1.

FB I Agents co nducted a non-custodial interv iew with Hunt w ho indicated that she had

never owned a business. Hunt also admitted to app ly ing for the loan and spending the proceeds on

bill s, items for her children, and gave money to so me of her re latives. Hunt told Agents that she

" knew it was wrong."

As a part of thi s plea the defendant admits that she knowingly made false statements to a

financial in stituti on for the purpose of obtaining a loan backed by the SBA. She also admits that

she vo luntarily and intenti onall y participated in a scheme to obtain money, affecting a financia l

instituti on, by means of making materially fa lse representations v ia an interstate wire

comm uni cati on and that she did so w ith the intent to defraud .

5. STATUTORY PENALTIES:

The defendant understands that the maximum possib le penalty as to each Count herein is

not more than 30 years of impri sonment, a fine of not more than $ 1,000 ,000, or both a fine and

imprisonment and a term of superv ised release of not more than fi ve years.

In the event defend ant is subj ect to any undi scharged or anti c ipated term of imprisonment

imposed by any co urt, defendant has been apprised by co un sel that the sentence imposed in this

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case may be imposed co nsec uti ve ly to the undi scharged or anti cipated term of impri so nment.

6. U.S. SENTENCING GUIDELINES: 2024 MANUAL:

The defe nd ant und erstands th at thi s offense is affected by the U .S. Sentencing Guid elines

and th e actu al se ntenc ing range is determin ed by both th e Total Offe nse Leve l and the Crimin a l

Hi story Category. T he parti es agree that the fo ll owing are the U .S. Sentencing Guide lines Total

Offense Leve l pro vis ions th at apply.

(1) Chapter 2 Offense Conduct:

(a) Base Offense Level: T he parti es agree that the base offense leve l is 7 as fo und

in Section 2B 1.1(a)( l ).

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

Spec ifi c Offense Characteri sti cs appl y: 4 levels should be added pursuant to Section

2Bl.l(b)(l)(C) because the loss exceeded $ 15,000.00.

(2) Chapter 3 Adjustments:

(a) Acceptance of Responsibility: T he parties recomm end th at two levels sho uld

be deducted pursuant to Sentencing Guidelines Secti on 3E 1.1 (a) because D efendant has c learly

demonstrated acceptan ce of res pons ibility.

The parti es agree th at if Defendant does not abide by all of th e agreements made w ithin

thi s doc um ent, Defend ant's fa ilure to co mpl y is ground s 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 eli g ibility for a reduction pursuant to Sentenc ing Guide lines Section 3E l.l is based

upon the informati on known at the present tim e and that any action s of Defend ant whi ch occ ur or

which beco me known to th e United States subsequent to this agreement and are inconsistent w ith

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Defendant's acceptance of responsibility including, but not limited to criminal conduct, are

gro unds for the loss of acceptance of responsibility pursuant to Sentencing Guidelines Section

3 E 1.1. In any event, the part ies agree that all of th e remaining prov isions of thi s agreement

remain valid and in full force and effect.

(b) Other Adjustments: The parties recommend that no additional adjustments app ly.

(d) Criminal History: The determination of the defendant's Criminal History Category

shall be left to th e Co urt. E ither party may challenge, before and at sentencing, the finding of the

Presentence Report as to the defendant's criminal history and th e applicable category. The

defendant's criminal hi story is known to the defendant and is substantially available in the

Pretrial Servi ces Report.

(e) Effect of Parties' U.S. Sentencing Guidelines Analysis: The parties agree that the

Co urt is not bound by the Guidelines ana lysis agreed to herein. The parti es may not have

foreseen all applicable Guidelines. The Co urt may, in its di scretion, apply or not apply any

Guideline despite the agreement here in and the parties sha ll not be perm itted to withdraw from

the pl ea agreement.

7. WAIVER OF APPEAL AND POST-CONVICTION RIGHTS:

a. Appeal: The defendant has been fully apprised by defense co unse l of the defendant's

ri ghts co ncernin g appeal and fully understands the right to appeal the sentence under T itle 18,

United States Code, Secti on 3742.

(1) Non-Sentencing Issues: The parties waive all ri ghts to appeal all non-jurisdictional,

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non-sentencing iss ues, inc luding, but not limited to, any issues re lating to pretri a l moti ons,

di scovery and the guilty plea, th e co nstitutionality of th e statute(s) to which th e defend ant is

pl eadin g guil ty and whether defendant's co ndu ct fall s w ithin the sco pe of the statute(s)

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

Sentencing Guide lines Total Offense Leve l agreed to here in, and , after determining a Sentencing

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

agreement, th e defendant hereby waives a ll ri ghts to appeal all sentencing iss ues oth er than

Criminal Hi story, but only if it affects the Base Offense Level or Criminal Hi story Category.

Similarly, the Governm ent hereby wai ves all ri ghts to appeal all se ntencing iss ues other than

Criminal Hi story, provided the Co urt accepts the plea, adopts the agreed Tota l Offe nse Level and

se ntences th e defendant w ithin or above that ran ge .

b. Habeas Corpus: The defend ant agrees to wa ive al I ri ghts to contest th e co nviction or

sentence in any post-conviction proceeding, including one pursuant to Title 28, U ni ted States

Code, Section 2255 , exce pt fo r c laims of prosecutorial mi sconduct or ineffecti ve ass istance of

co unsel.

c. Right to Records: The defend ant waives a ll ri ghts, whether asse rted directly or by a

representative, to requ est from any departm ent or agency of the United States, any record s

pertaining to the in vesti gati on and prosecuti on of thi s case, including any record s that may be

so ught under the Freedom ofln fo rm ati on Act, Titl e 5, United States Code, Secti on 522, or th e

Privacy Act, Title 5, United States Code, Section 552(a) .

8. OTHER:

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

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to truthful ly compl ete and sign fo rm s as required by the United States Pro bati on Office pri or to

sentencing and conse nts to th e release of these fo rm s and any supporting doc umentation by the

United States Pro bati on Office to th e governm ent.

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

Nothin g co nta ined here in limits th e ri ghts and auth ority of th e United States to take any

civ il , tax, immigrati on/deportatio n or admini strati ve acti on against th e defendant.

c. Supervised Release: P ursuant to any supervised release term , the Co urt w ill impose

standard co ndit ions upon the defendant and may impose speci al conditions related to the crime

the defend ant committed. These co ndit ions w ill be restri cti ons on the defendant to which the

defendant w ill be required to adh ere. Violati on of the co nditi ons of supervised release res ulting

in revocati on may require the defendant to serve a term of impriso nment equ al to the length of

the term of supervised release, but not greate r than the term set fo rth in T itl e 18, Uni ted States

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

understands that paro le has been aboli shed .

d. Mandatory Special Assessment: Pursuant to Titl e 18, United States Code, Secti on

301 3, the Co urt is required to impose a mand atory special assessment of $ 100 per co unt for a

tota l of $200 , whi ch the defendant agrees to pay at th e tim e of se ntencing. Mo ney pa id by th e

defe ndant toward any restituti on or fi ne imposed by the Co urt shall be first used to pay any

unpaid mandatory spec ial assessment.

e. Possibility of Detention: The defendant may be subj ect to immedi ate detenti on

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

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impose a fin e, costs of incarcerati on and costs of supervision. The defendant agrees th at any fin e

imposed by th e Co urt w ill be due and payable immedi ately. The defend ant agrees to pay

$ 19,870 .00 in restituti on to th e United States of Am erica.

g. Forfeiture: The defendant knowingly and vo luntarily wai ves any ri ght, title, and interest

in all items se ized by law enfo rcement offi cial s durin g th e course of the ir investi gati on, whether

or not th ey are subj ect to fo rfe iture, and agrees not to co ntest th e vesting of title of such items in

th e United States. The defendant agrees to abandon [hi s/her] interest in all seized items and furth er

agrees that said items may be disposed of or destroyed by law enfo rcement offi cials in any manner

without furth er notice. By aband onin g th ese items, th e defend ant waives any future rights to

receive additional noti ce, a valuation of the items, or the opportunity to submit a claim to contest

the di sposition or destructi on of the items th at may exist und er any policies or procedu res of th e

seizing agency(i es ).

9. ACKNOWLEDGMENT AND WAIVER OF THE DEFENDANT'S RIGHTS:

In pl eadin g guilty, the defe ndant acknowledges, full y understands and hereby waives his

ri ghts, including but not limited to: the ri ght to pl ead not guilty to th e charges; the right to be

tri ed by a jury in a publi c and speedy tri a l; the ri ght to fil e pretrial motions, including mot io ns to

suppress or exclude evidence; th e ri ght at such trial to a presumption of innocence; the ri ght to

require th e governm ent to prove the e lements of th e offenses charged against the defendant

beyond a reaso nabl e doubt; th e ri ght not to testify; the ri ght not to present any ev idence; the ri ght

to be protected from compelled self-incrimination; the right at trial to confront and cross-

examine ad verse witnesses; the ri ght to testify and present evidence and the ri ght to compe l th e

attendance of w itnesses. The defendant furth er understands that by thi s guilty plea, the

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defendant express ly waives all the rights set forth in thi s paragraph .

The defendant full y understands that the defendant has the ri ght to be rep resented by

co un sel, and if necessary, to have the Co urt appoint co unsel at trial and at every other stage of

the proceeding. The defend ant's co unse l has explained these ri ghts and the consequences of the

waiver of these rights. The defendant fully understands that, as a result of the guilty plea, no trial

will, in fact, occur and th at the onl y action remaining to be taken in thi s case is the imposition of

th e sentence.

The defendant is full y satisfied w ith the representation rece ived from defense counsel.

The defendant has rev iewed th e govern ment' s evidence and di scussed the governm ent's case and

all possible defenses and defense w itnesses with defense co unsel. Defense counsel has

completely and satisfactoril y exp lored a ll areas which th e defendant has requested relative to th e

government's case and any defenses.

The term s and conditi ons contained in thi s stipul ation constitute th e only plea offer which

has been tendered to the defendant by th e Government here in . Defendant has fully discussed the

terms and conditions of th e offer w ith co un se l and the defendant understands and agrees to the

same.

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

Thi s document co nstitutes the entire agreement between th e defe ndant and the

government, and no other promi ses or inducements have been made, directl y or indirectly, by

any agent of the governm ent, including any Department of Ju stice attorney, concerning any plea

to be entered in thi s case. In add iti on, the defendant states that no perso n has, directly or

indirectly, threaten ed or coerced the defendant to do or refrain from doing anything in
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co nnecti on w ith any aspect of thi s case, inc luding entering a plea of g uilty .

The defend ant ackn owledges hav ing vo luntaril y entered into both th e pl ea agreement and

the guilty plea. The defe nd ant furth er ackn owledges that thi s guilty pl ea is made of the

defendant's own free w ill and that th e defendant is, in fact, g uil ty.

11. CONSEQUENCES OF POST-PLEA MISCONDUCT:

After pleadin g guilty and befo re sentenc ing, if defe ndant co mmits any crime, other th an

min or traffi c offenses, violates any co ndi tions of re lease that res ults in revocati on, vio lates any

term of this guil ty-pl ea agreement, intentio na ll y prov ides mi sleading, inco mpl ete or untruthful

informati on to th e U.S . Probation Office or fa il s to appear fo r sentenc ing, th e Uni ted States, at its

option may be re leased from its obli gati o ns under thi s agreement. T he Gove rnm ent may a lso, in

its di scretion , proceed with thi s agreement and may advocate for any sentenc ing pos iti on

supported by th e facts, inc luding but not limited to obstruction of justi ce and deni a l of

acceptance of responsibili ty.

12. NO RIGHT TO WITHDRAW GUILTY PLEA:

Pursuant to Rul e 11 (c) and ( d), Federal Rul es of Crimina l Procedure, th e defendant

understands th at th ere w i II be no ri ght to w ithdraw the plea entered und er th is agreement, except

where th e Co urt rej ects those port ions of the plea agreement whi ch deal with charges the

governm ent agrees to di smiss or not to bring.

-t- 1f/t ZoZ f"'
Date
r:z;va
Tim J. Willi s,# 6242 8MO
Ass istant United States Attorney
555 Independ ence Street, Suite 3000

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Cape Girardeau, M isso uri 63703

Date
~o&l -
Victoria Natas ha Hunt
+tJ
Defendant

Date Philip Ei nhauer
Attorney at Law
101 5 Loc ust St. Unit 1000
St. Loui s, MO 63 101

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