Guilty Plea Agreement — U.S. v. Jai Dawness Hunt (E.D. Mo.)

Summary

A guilty plea agreement in United States of America v. Jai Dawness Hunt, Case 1:25-cr-00044-SEP, in the United States District Court for the Eastern District of Missouri, filed July 22, 2025 as Doc. #: 29. The defendant agrees to plead guilty to the indictment, charging a false statement to a financial institution and wire fraud, and to pay $20,000.00 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 false IRS Schedule C, and that Benworth deposited the $20,000.00 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; the signature block names Tim J. Willis for the government.

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“Guilty Plea Agreement — U.S. v. Jai Dawness 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-29-e-d-mo-5156425c5d/, SHA-256 8ddcf9ed0a59ad17651a361badfaafd18a37e642f8d9484aa21119f1ab113041.

Full text

Case: 1:25-cr-00044-SEP Doc. #: 29 Filed: 07/22/25 Page: 1 of 12 PageID #: 84

FILED
UNITED STATES DI STRICT COURT
EASTERN DISTRICT OF M ISS O URI JUL 22 2025
SOUT HEASTERN DIVISION U. S. DISTRICT COURT
EASTERN DISTRICT OF MO
CAPE GIRARDEAU
UNITED ST ATES OF AMERICA, )
)
Pl a intiff, )
) N O. 1:25 CR 44 SEP
V. )
)
JAi DA WNESS H UNT, )
)
Defend ant. )

GUILTY PLEA AGREEMENT

Come now the part ies and here by agree, as fo ll ows:

1. PARTIES:

The parties are the defend ant Ja i Dawness Hunt, represented by defense co unsel P hilli p

R. Donneyer, and the United States of America, (here inafter "gove rnm ent"), rep resented by the

Office of th e United States Attorney for the Eastern Di strict of Mi sso uri . This agreement does

not, and is not intended to, bind any governm enta l offi ce or agency other th an the Uni ted States

Attorn ey for th e Eastern Di strict of M isso uri . The Co urt is ne ither a party to nor bound by thi s

agreement.

2. GUILTY PLEA:

Pursuant to Rul e 11 (c)( l )(A), Federa l Rul es of Crimina l Procedure, in exchange for

defendant's vo luntary pl ea of guil ty to th e indictment, th e government agrees that no fu rther

federal prosecuti on of the defendant will be bro ught in thi s Di stri ct re lati ve to th e und erly ing

facts supporti ng th e charges in the indi ctment herein, of whi ch th e government is aware at th is

tim e. The defend ant also agrees to pay $20,000 .00 in restitution to th e U nited States of Ameri ca
Case: 1:25-cr-00044-SEP Doc. #: 29 Filed: 07/22/25 Page: 2 of 12 PageID #: 85

as a part of this plea .

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

U.S. Sentencing Guidelines range (co mbinat ion of Total Offense Level and Crimina l History

Category) ultimately determined by the Co urt pursuant to any chapter of the Guidelines, Title 18

United States Code, Section 3553, or any other prov ision or rul e of law not addressed herein. The

part ies furth er agree that notice of any such request w ill be given no later than ten (10) days prior

to sentenc ing and that said notice shall spec ify the legal and factual bases for the request.

3. ELEMENTS:

The crime of making a fa lse statement to a financia l institution, as charged in Count I of

the Indictment, has three e lements, which are: One, the defendant knowingly made fa lse

statements, name ly that the defendant was the owner of a qu alify ing small business, and that PPP

loan proceeds wo uld be spent on permissible expenses, to a financial institution; Two , the

defendant made the false statement for the purpose of influenc ing the action of the fi nanc ia l

institution upon an application for a PPP loan; and Three , that the loan was backed by the Small

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

The crime of w ire fraud , as charged in Co unt II of the indictment, has fo ur elements, which

are: One, th e defendant vo luntarily and intentiona lly partic ipated in a scheme to obtain money by

means of materi al fa lse representations, namely the submiss ion of a fraudulent PPP Loan

app licati on, Two, the defend ant did so with the intent to defraud ; Three, th e defendant used, or

caused to be used, an interstate wire communi cation, that is, use of an internet loan application

portal, in furtherance of some essential step in the scheme; and Four, th e scheme affected a

financia l institution.

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4. FACTS:

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

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

co ns idered as relevant co nduct pursuant to Section lBl. 3:

The Coro nav iru s A id , Relief, and Eco nomi c Security ("CARES") Act is a federa l law

that was enacted in or around March of 2020 to provide emergency financial ass istance to the

millions of Ameri cans suffer ing the eco nomic impact caused by the COV ID-1 9 pandemic. The

CARES Act authorized the Smal l Business Administrati on (SBA) to iss ue forgivable loans to

sma ll businesses for job retention and ce1ia in oth er expenses through th e Paycheck Protection

Program ("PPP").

To obta in a PPP loan , a qua lifyi ng business was required to submit a PPP loan

app licati on, signed by an authorized representative of the business who was required to certify

that, amo ng oth er things, the sma ll bu siness was in operatio n on Febru ary 15, 2020, and that

SBA loan proceeds w ill be used on ly for business-related purposes as spec ified in the loan

app li cation and cons istent with the Paycheck Protection Progra m Rules, such as retaining

worke rs, maintaining payrol l, making mortgage interest payments, lease payments, and uti lity

pay ments. The program a lso required the submi ss ion of certain docum ents re lated to the identity

of the appli cant and th e expenses of the business, like payroll, that wo uld be covered by the

loans.

Jai Dawness Hunt of Caruth ersv ill e, Pemiscot County Missouri was identified as a perso n

who had fil ed via an interactive intern et portal, whi ch co nstitutes an interstate w ire

communication, a fraudul ent applicati on for a PPP loan w ith Benworth Capital Partners, LLC, of

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Coral Gabl es Florida. Benwo rth was an SBA appro ved fin anc ia l in stitution fo r th e PPP Loan

program. Jai Hunt did not own or operate an e li gible business and had submitted a fraudul ent IRS

Schedul e C to obtain th e loan. Jai Hunt had also upl oad ed a copy of her photo and M isso uri dri ver' s

license to th e website to prove her identity. Jai Hunt applied for a loan on April 22, 202 1, and

Benworth depos ited th e proceeds, $20,000.00 into her bank acco unt on May 17, 202 1.

Agents conducted a non- custodial interv iew of Hunt wh o admitted th at she had gotten the

money but did not own a business in 2020. Hunt also indicated th at she didn ' t make th e income

li sted on her IRS Schedule C, and that she had used the money to try and start a business and go

to schoo l.

As a part of thi s plea the defendant admits that she know ingly made fa lse statements to a

finan cial institution for the purpose of obtaining a loan backed by the SBA. She also admits th at

she vo luntaril y and intentiona ll y parti cipated in a scheme to obtain money, affecting a fi nancial

instituti on, by means of making materi all y fal se representations via an interstate w ire

communicati on and that she did so w ith the intent to defraud.

5. STATUTORY PENALTIES:

The defend ant understands that the max imum poss ibl e penalty as to each Co unt here in is

not more than 30 years of imprisonment, a fin e of not more than $ 1,000,000, or both a fin e and

impriso nment and a term of supervised re lease of not more than fi ve years.

In the eve nt defend ant is subj ect to any undi scharged or anti cipated term of impri so nment

imposed by any court, defe ndant has been appri sed by counse l that the sentence imposed in this

case may be imposed consecuti ve ly to the undi scharged or anticipated term of impri so nment.

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

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The defendant understands that thi s offense is affected by the U.S. Sentencing Guideli nes

and th e actua l se ntenc ing ran ge is determined by both th e Total Offense Level and the Crim inal

History Category. The parties agree that the fo ll owi ng are the U.S. Sentenc ing Guide lines Total

Offense Leve l provisions that app ly.

(1) Chapter 2 Offense Cond uct:

(a) Base Offense Level: The parti es agree that the base offense level is 7 as found

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

(b) Specific Offense Characteristics: T he parties agree that the fo llowing

Spec ifi c Offense Characteristics appl y: 4 leve ls should be added pursuant to Section

2B I. I (b)(1 )(C) because the loss exceeded $15 ,000 .00.

(2) Chapter 3 Ad justments:

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

be deducted pursuant to Sentencing Guide lines Section 3E l.1 (a) because Defendant has clearly

demo nstrated acceptan ce of responsibility.

The parties agree that if Defendant does not ab ide by al l of the agreements made within

this doc um ent, Defend ant's fa ilure to co mpl y is gro unds fo r the loss of acceptance of

responsibi lity pursuant to Sentenci ng Guide lines Section 3E I . I. T he parties further agree that

Defendant's eli gibility for a reduction pursuant to Sentenc ing Guide Iines Section 3E 1.1 is based

upon the informat ion known at the present time and that any actions of Defendant w hi ch occur or

whi ch become known to the United States subseq uent to this agreement and are incons istent with

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

gro unds for the loss of acceptance of respo nsibility pursuant to Sentenci ng Guidelines Section

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3E l .1. In any eve nt, th e parties agree th at all of th e rema ining p rov isions of thi s agreement

remain valid and in full force and effect.

(b) Other Adjustm ents: The parties recommend th at no additi ona l adj ustments app ly.

(d) Criminal History: The determin at ion of th e defend ant's Crimin al H istory Category

shall be left to the Co urt. E ither party may cha llenge, befo re and at sentenci ng, the fi nd ing of the

Presentence Report as to the defendant's crimin al hi story and th e applicabl e category . The

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

Pretri al Services Report.

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

Co urt is not bound by the Gui de lines ana lys is agreed to herein. The parti es may not have

fo reseen all appli cable Guid elines. The Co urt may, in its di scretion, apply or not apply any

Guid eline despite the agreement here in and the parties shall not be permitted to w ithdraw fro m

the plea agreement.

7. WAIVER OF APPEAL AND POST-CONVICTION RIGHTS:

a. Appeal: The defendant has been full y appri sed by defe nse co unse l of th e defendant's

ri ghts co ncerning appeal and fully und erstands the ri ght to appeal the sentence under Title 18,

United States Code, Sectio n 3742.

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

non-sentenc ing iss ues, including, but not limited to, any issues re lating to pretrial motions,

discovery and th e guilty plea, the co nstitut ionality of th e statute(s) to which the defend ant is

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pleading guilty and whether defendant's conduct falls w ithin the scope of the statute(s)

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

Sentencing Guidelines Total Offense Leve l agreed to herein, and, after determining a Sentencing

Guidelines range, sentences the defendant w ithin or below that range, then , as part of this

agreement, the defendant hereby waives a ll rights to appea l all sentencing iss ues other than

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

Similarly, th e Government hereby waives all rights to appeal all sentenc ing issues other than

Criminal Hi story, provided the Court accepts the plea, adopts the agreed Total Offense Level and

sentences the defendant within or above that range.

b. Habeas Corpus: The defendant agrees to waive all ri ghts to contest the conviction or

se ntence in any post-conviction proceeding, including one pursuant to Title 28, United States

Code, Section 2255, except for claims of prosecutorial misconduct or ineffective assistance of

counsel.

c. Right to Records: The defendant waives a ll rights, whether asserted directly or by a

representative, to req uest from any department or age ncy of the United States, any records

pe1iaining to th e investi gation and prosecution of this case, including any records that may be

so ught under the F reedom of Information Act, Title 5, Un ited States Code, Section 522, or the

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

8. OTHER:

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

to truthfully complete and sign forms as required by the United States Probation Office prior to

sentencing and consents to the release of these forms and any supporting documentation by the

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United States Probation Office to the governme nt.

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

Nothing contained herein limits the rights and authority of the United States to take any

civ il , tax, immigration/deportation or administrative action against the defendant.

c. Supervised Release: Pursuant to any superv ised release term, th e Court will impose

stand ard co nditions upon the defendant and may impose spec ial conditions related to the crime

the defend ant committed. These conditions w ill be restrictions on the defend ant to which the

defendant w ill be required to adhere. Vio lation of the conditions of superv ised re lease resulting

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

the term of superv ised release, but not greater than the term set forth in Title 18, United States

Code, Section 3583(e)(3), without credit for the time served after release. The defendant

understands th at parole has been abo li shed.

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

301 3, the Co urt is req uired to impose a mandatory spec ial assessment of$ 100 per count for a

total of $200, whi ch the defendant agrees to pay at the tim e of sentenc ing. Money paid by the

defendant toward any restitution or fine 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 detention

pursuant to the provis ions of Title 18, United States Code, Section 3 143.

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

impose a fine, costs of incarceration and costs of superv ision . The defendant agrees that any fine

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

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$20,000.00 in restituti on to the U nited States of America.

g. Forfeiture: The defendant knowing ly and vo luntarily waives any right, title, and interest

in al I items seized by law enforcement official s durin g the course of the ir investigation, whether

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

the United States. The defendant agrees to abandon [his/her] interest in a ll seized items and further

agrees that said item s may be di sposed of or destroyed by law enforcement officials in any manner

without further notice. By abandonin g these items, the defendant waives any future rights to

rece ive additional notice, a va luation of the items, or th e opportunity to submit a claim to contest

the di sposition or destruction of the items that may exist under any poli cies or procedures of the

se izing agency(ies ).

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

In pleading guilty, the defendant acknowledges, fully understands and hereby waives hi s

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

tri ed by a jury in a public and speedy trial ; the ri ght to fi le pretrial motions, including motions to

suppress or exclude ev idence; the ri ght at such trial to a presumpti on of innocence; the right to

require the government to prove the elements of the offenses charged against the defendant

beyond a reaso nable doubt; the right not to testify; the right not to present any ev idence; the right

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

examine adverse witnesses; the right to testify and present evidence and th e ri ght to co mpe l the

attendance of witnesses. The defendant further understands that by this guilty plea, the

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

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

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

the proceeding. The defe nd ant's co un se l has expl a ined th ese ri ghts and the consequ ences of th e

wa ive r 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

will , in fact, occur and th at the onl y act io n remaining to be taken in thi s case is th e impos ition of

th e sentence .

The defend ant is fu lly satisfi ed w ith th e representation rece ived from defense counsel.

The defend ant has rev iewed the governm ent's evidence and di sc ussed the governm ent's case and

all poss ible defe nses and defense witnesses w ith defense co unsel. Defense co unsel has

completely and sati sfactoril y explored a ll areas whi ch the defendant has requested re lati ve to the

governm ent's case and any defenses.

The terms and co nditi ons co nta ined in thi s stipulation constitute th e onl y plea offer which

has been tend ered to th e defend ant by the Governm ent herein. Defendant has full y di scussed th e

term s and co nditi ons of the offe r w ith co unse l and th e defendant understands and agrees to th e

sam e.

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

Thi s docum ent co nstitutes th e entire agree ment between th e defe ndant and the

governm ent, and no oth er pro mises or inducements have been made, directl y o r indi rectly, by

any agent of th e governm ent, including any Departm ent of Justi ce attorney, co ncerning any plea

to be entered in thi s case. In additi on, the defe nd ant states that no perso n has, directly or

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

co nnecti on with any aspect of this case, including enterin g a plea of g uilty.

The defend ant acknowledges hav ing vo luntaril y entered into both th e plea agreement and

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th e guilty pl ea. The defend ant furth er ackn owledges that thi s guilty pl ea is made of the

defendant' s own free will and that the defendant is, in fact, guilty.

11. CONSEQUENCES OF POST-PLEA MISCONDUCT:

After pleading guil ty and befo re sentenc ing, if defendant commits any crim e, other than

min or traffi c offenses, violates any conditions of re lease that results in revocati on, violates any

term of this guilty-plea agreement, intenti ona ll y prov ides misleading, inco mpl ete or untruth ful

information to the U.S. Pro bati on Offi ce or fail s to appear for sentencin g, th e United States, at its

option may be re leased from its obligati ons under thi s agreement. The Governm ent may also, in

its di screti on, proceed w ith thi s agreement and may advocate for any se ntencing pos ition

supported by the facts, inc luding but not limited to o bstruction of justice and deni al of

acceptance of responsibility.

12. NO RIGHT TO WITHDRAW GUILTY PLEA:

Pursuant to Rul e 1l (c) and (d), Federal Rul es of Criminal Procedure, the defendant

understands that th ere will be no right to w ithdraw the plea entered und er this agreement, except

where the Court rej ects th ose porti ons of th e pl ea agreement which deal with charges the

government agrees to di smi ss or not to bring.

?7ra
Tim J. Willis, # 62428MO
Ass istant United States Attorney
555 Independ ence Street, Suite 3000
Cape Girardeau, Mi ssouri 63703

~~Hu~~
Defendant

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Phillip R . Dorm eyer
Attorn ey at Law
l 07 S. Broadv iew
Cape Girardeau, M isso uri 63703

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