Cindi Denton — Affidavit, Paycheck Protection Program

Summary

Affidavit by Sarah Conlon in support of a criminal complaint charging Denton with wire fraud, bank fraud, and attempt and conspiracy to commit wire fraud and bank fraud in the Southern District of Florida. The affidavit states that Denton obtained a PPP loan for Emerald Jade Solutions, Inc., with CHS 2 providing falsified documents and submitting the application. It states that Denton sent wires totaling approximately $175,860, including a $150,000 wire, and made cash withdrawals of $9,900 each. It also describes a controlled call placed by CHS 3 to Denton.

Summary drafted by a model from the document's text below 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

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“Cindi Denton — Affidavit, Paycheck Protection Program.” Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/crim-flsd-0-21-cr-60171-u-s-v-cindi-denton-docx-complaint-1e4fe32193/, SHA-256 c3bf6d73ae7a5e20632e91550ad61925c88469e01dcaa6ba3b341377af9966cb.

Full text

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A FFIDA VIT
1,Sarah Conlon,being srstduly sworn,hereby depose and state as follows:

INTR O DUC TIO N A ND A G ENT BACK G RO UN D
lm ake this A ffidavitin supportofa crim inalcom plaintcharging CIN DI ELLIS

DENTON (SIDENTON''or'lllefendant''),withwirefraud,bankfraud,andattemptandconspiracy
tocommitwirefraudand bankfraud,inviolationof18U.S.C.jjl343,1344,1349,and2,from
on or aboutJune 1,2020,to atIeaston orabout Septem ber30,2020,in the Southern Districtof

Florida,and elsewhere(the 'û-l-argetOffenses'').
Defendanthas participated in a conspiracy and schem e to obtain by fraud m illions

of dollars in forgivable loans through the Paycheck Protection Program (:çPPP'') and other
governm entprogram s. Defendantcom m itted the TargetO ffenses with a person now cooperating

withtheinvestigation (ttCHS 2'5)andothers. DefendantobtainedafraudulentPPP Ioan forher
own company,Emerald Jade Solutions,Inc.(çkEmerald Jade''),with CHS 2 providing falsifsed
docum entsand subm itting the application on Defendant's behalfin exchange fora kickback from

the loan proceeds. To intlate the size of these PPP loans,and the corresponding kickbacks,the

conspirators relied on a variety of false statem ents, including by subm itting falsified bank

statem entsand payrolltax form s. Forexam ple,the conspirators used nearly identicalversions of
the sam e fabricated bank statem ents,recycled in the PPP applicationsform ultiple companies,w ith

m inorchanges.
The conspirators in the schem e planned or prepared at least 90 fraudulent

applications,m ostofw hich were subm itted. Based on the evidence investigators have reviewed

to date,CHS 2,Defendant,and theirco-conspiratorsapplied f0rPPP loansthatare togetherworth

morethan $34 m illion,with atleastapproximately 42 ofthose loansapproved and funded fora
totalofapproximately $l7.6 million. Certain ofthose loan recipientsthen wired akickback of

varying am ounts, often approximately 25% of the fraudulent Ioan proceeds, to an account

controlled by CH S 2.
lam a SpecialA gentw ith the United States Departm entofthe Treasufy,Internal

RevenueService,Criminallnvestigation(%kIRS-CI--)andhavebeenemployedinthiscapacitysince
N ovem ber2018. Iam presently assigned to the M iam iField Oftsce.M y dutiesasa SpecialAgent

includetheinvestigation ofpossiblecriminalviolationsoftheInternalRevenueCode(Title26of
theUnitedStatesCode),theBankSecrecyAct(Title31oftheUnitedStatesCode),andtheMoney
Laundering Statutes (Title l8 of the United States Code). Igraduated from the Criminal
lnvestigatorTraining Program atthe FederalLaw Enforcem entTraining Center in M arch 2019

and the SpecialAgent lnvestigative Techniques program atthe NationalCrim inalInvestigation

Training Academy in June 20l9. In these tw o program s,lstudied a variety oflaw enforcem ent

tactics and crim inalinvestigatortechniques relating to tax and financialcrim es. Since becom ing

an IRS-CISpecialA gent,lhave personally investigated and assisted in investigationsrelating to

the InternalRevenue Laws and tsnancialcrim es. Recently,Ihave been assigned to w ork with the

U .S.DepartmentofJustice and other Iaw enforcem entpartners,including the FederalBureau of

Investigation and the SmallBusiness A dm inistration Office of InspectorG eneral,to investigate

possible fraud associated w ith the stim ulus and econom ic assistance program s created by the

federalgovernm entin response to the COV ID-l9 pandem ic.

The facts in this A ffidavitcom e from my personalobservations,my training and

experience,and inform ation obtained from otherm em bersoflaw enforcem entand from w itnesses.

Page 2 of 14
This Affidavitis intended to show m erely thatthere is suffscientprobable cause and doesnotset

forth alIofmy know ledge aboutthism atter.l

PR O BA BLE C AUSE

The Pavcheck Protection Prozram

6, ThcCoronavirusAid,Relicf,andEconomicSecurity(-CCARES'')Actwasafederal
law enacted in oraround M arch 2020 and designed to provide em ergency financialassistance to

the m illions of Am ericans w ho are suffering the econom ic effects caused by the COV ID-I9

pandem ic. O ne source ofrelief provided by the CA RES A ctw asthe authorization offorgivable

loanstosmallbusinessesforjobretentionandcertainotherexpenses,throughaprogram referred
toasthePaycheck Protection Program ('iPPP'').
7. ln order to obtain a PPP loan, a qualifying business subm itted a PPP loan

application,which was signed by an authorized representative ofthe business. The PPP loan

application required the business (through its authorized representative) to acknowledge the
program rules and m ake certain affirmative certifications in orderto be eligible to obtain the PPP

loan.InthePPP Ioan application (SmaI1BusinessAdministration(i;SBA'')Form 2483),thesmall
business(through itsauthorized representative)wasrequired to provide,among otherthings,its:
(a)averagemonthlypayrollexpenses;and(b)numberofemployees.Thesefigureswereusedto
calculate the am ount of m oney the sm allbusiness w as eligible to receive under the PPP. In

addition,businesses applying fora PPP loan were required to provide docum entation confsrm ing

theirpayrollexpenses.

l The conductand charges described in thisA ffidavitare partofa Iarger investigation that
is being conducted in this D istrict and elsewhere. As a result,not allnum bered sources and
anonym ousindividualsand entities are described in every filing. lhave included in this Affidavit
only those individualsand entities Ihave deem ed necessary to explain theparticularfactssetforth
here.

Page3 of14
A PPP loan application was processed by a participating lender. If a PPP loan

application was approved,the participating lender funded the PPP loan using its own m onies.

W hile itw asthe participating lenderthatissued the PPP Ioan,the loan was l00% guaranteed by

the SBA . Data from the application,including inform ation aboutthe borrower,the totalamount

ofthe loan,and the listed num berofem ployces,w astransm itted by the lenderto the SBA in the

course ofprocessing the Ioan.
PPP Ioan proceedsw ere required to be used by the businesson certain perm issible

expenses payrollcosts,intereston m ortgages,rent,and utilities. The PPP allow ed the interest

and principalon the PPP loan to be entirely forgiven ifthe business spentthe loan proceeds on

these expense item sw ithin a designated period oftim e and used a defsned portion ofthe PPP loan

proceedsOn payrollexpenses.

Finand alInstitutions
ThisA ffidavitreferencesfinancialinstitutionsthatare headquartered in the United

Statesand insured by the FederalDepositInsurance Corporation,including Bank 1,Bank 3,Bank

5,Bank 6,and Bank 7.

The Schem e to Obtain FraudulentPPP Loans

On oraboutM ay l3,2020,Phillip J.Augustin (çiAugustin'')and CHS 2 worked
togetherto subm ita fraudulentPPP loan application on behalfofa com pany owned by Augustin.

Augustin submitted aPPP loan of$84,5l5 to afederally insured bank (hereinafterSkBank 3'9),
through a third-party company processor (hereinafter tûBank Processor 15'). The application
included bank statem entsthatare clearforgeries,and CHS 2 hasadm itted thatthe application w as

based on docum entsthathe falsified forA ugustin.

Page4 of 14
Follow ing the successofthatinitialfraudulentPPP application,Augustin and CHS

2 began to work on obtaining m ore and larger PPP loans forA ugustin's associates and others,

generally forseveralhundredthousanddollarsforeach Ioan,uptoasmuch asapproximately$1.24

n'
1i11ion.
On June 25, 2020, investigators arrested CH S 2 and another person now

cooperating with the investigation (SSCHS 35')and executed search warrantsattheirresidences.
Follow ing theirarrests,C HS 2 and CHS 3 chose to cooperate with the investigation in the hope of

obtaining favorable consideration in connection with their pending charges. CH S 2 was

interviewed on that day, and has continued to cooperate w ith the investigation after obtaining

counsel. CHS 3 has also been interview ed num erous tim es and hascontinued to cooperate w ith

the investigation after obtaining counsel. M ost of the statem ents related herein have been

corroborated by records obtained from third parties or recovered from CH S 2's and CH S 3's

respective electronic devices.
l4. Based on the evidence investigators have reviewed so far,CHS 2 and Augustin

collectively coordinated applicationsforPPP loansthataretogetherworth morethan$34 million

dollars.Theevidencealso showsmanymorePPPloanswereattemptedbutrejectedbybanksor
their partners, or w ere planned and prepared, but not subm itted before CHS 2's arrest. The

evidence suggests that all or nearly al1 of those loan applications were fraudulent, including

Defendant's loan application.

lnvestigators have obtained m any other PPP Ioan applications that CHS 2 has

adm itted he subm itted aspartofthisschem e,based on falsified docum ents,and have also obtained

draftdocum entsused orintended to be used in thoseapplicationsorothers. These applicationsall

follow the sam e pattern of fraud m any w ith obviously counterfeit February 2020 bank

Page 5 of14
statements,and a1Iwith fabricated IRS Form s94l (titled,tiEmployer's Quarterly FederalTax
Return'')withthesameindiciaoffraudfound inAugustin'sinitialapplication butgenerallywith
even larger intlated payrollnum bers,thus yielding m uch larger loans.2 CH S 2 has explained to

investigatorsthatthe figures in the Form s 94 1 were the productofa form ula thatallowed him to

startw ith atargetloan am ount,and then -kback into''the payrollfigurcson the form . He explained

how he used figuresthatwould producean averagem onthly payrollfor2019 that,w hen m ultiplied

by 2.5,would yield the requested loan am ount. In turn,the num berof em ployees reported was

chosen based on fsctionalpayrollfigures,chosen to avoid an average em ployee salary thatm ight

raise suspicion.
CHS 2 has also explained thathe tried to use bank statem ents show ing that the

com pany had a large balance. Because so few com panies had such a statem ent,and likely also

because itwaseasierthan keeping track oftheirtrue statem ents,CH S 2 repeatedly subm itted near-

replicas ofthe sam e falsified bank statem ents. In particular,CH S 2 appearsto have recycled one

statem ent each from Bank 1,Bank 6,and Bank 7. ln recycling a statem ent,CH S 2 generally

changed only the account num ber and the account holder's nam e and address,such that each

version ofthe statem enthad identicalfiguresand Iine item sthroughoutthe statem ent.

A review ofrecords for bank accounts controlled by CH S 2 at Bank 5 confirm ed

CH S 2's adm issions that he received num erous kickbacks,often of approxim ately 25% of the

am ountofthe Ioans,and thathe regularly w ired A ugustin a share ofthatkickback in the early

stagesofthe schem e. CHS 2 explained thatthey were doing so m any loansby theend ofM ay that

2 Some loan applications also included voided checksthatappearto be falsified,such asa
purported check from a bank (:iBank 5'')thatappearsto have been produced on acomputerand,
asthesubjectlineofanemailtransmittingthevoidedcheckread,tûconverted to PDFg,1''rather
than a scan ofan authentic check.

Page6 of 14
he changed course,instead wiring largerlum p sum sscollecting A ugustin's sharesofthe kickbacks

fbrm ultiple loans in one w ire.
18. lnvestigatorsare stillreceiving and analyzing records,butbased on a prelim inary

analysis,asofAugust31,2020,investigatorshadidentitsed atotalofapproximately $2,367,765.82
in transfersto CH S 2'saccounts from entitiesthateach obtained a sizable PPP loan and thatwere

identitsed in the PPP files seized from CH S 2's and another co-conspirator's residences, as

described below or from individualsassociated with those entities.

19. The PPP loans identitsed above as im plicated in the foregoing kickback paym ents

to CHS 2 representonly a fraction of the overallschem e. ln executing search warrants at the

respective residencesof CHS 2 and CHS 3,federalagents found stacks ofpaperprinted outand

organized by entity,containing an kkintake form ,''fabricated Form s 941,orboth for each entity.

The intake form s contained fields forthe inform ation needed to fabricate the docum entsand t5ll

outother aspects of the PPP application:identifying inforlmation aboutthe ow nerand com pany,

asw ellasbank accountinform ation forreceiving the Ioan. A section attheend m arked CûBELO W

IS OFFICE USE ONLY''included blank fieldsforthe û'NumberofEmployeesg,l''ikMonthly
PayrollExpensegsl''and ISSBA Loan Pre-ApprovalAmount.'' Between CHS 2'sand CHS 3's
residences,investigatorsseized paperfilesforPPP Ioan applicationsforapproxim ately 80 different

entities.

20. D ata obtained from the SBA showed additional PPP Ioan applications from

additional entities that text m essage and em ail records show had been referred to CH S 2 by

m em bersofthe conspiracy.
21. According to CHS 3,hem etD EN TON through unrelated businessventures in early

2020. CH S 3 subsequently contacted DENTON regarding the PPP conspiracy described above.

Page 7 of14
The FraudulentPPP Loan D lsbursed to DEN TON 'S Com panv:Em erald Jade Solutions.Inc.

22. According to California's Secretary ofState website,Em erald Jade wasestablished

asa California corporation on oraboutDecem ber 11,2013. D EN TON is listed asthe com pany's

ChiefFinancialO fficerand D irector. Em erald Jade has notm ade any Glingsw ith the California

Secretary of State since 20l9 and its status is listed asktsuspended-'on California's Secretary of

State website. The m ailing address of Em erald Jade included on California's Corporations

D ivisionw ebsite isthe sam e addressthatappeared on DENTON 'SCalifornia Departm entofM otor

Vehicles records at the tim e DEN TON subm itted,or caused the subm ission of,the PPP loan

application forEm erald Jade.3

23. On oraboutJune l,2020,D ENTON sentCH S 3 a com pleted version ofthe kiintake

form''from DENTON'Semailaddressof-kcindi@emeraldjadesolutions.com.''UnderthePersonal
lnform ation heading, DENTON included her social security num ber and date of birth, and

DENTON usedtheemailaddresstecindi@ emeraldjadesolutions.com''andthephonenumber949-
633-2618 (DENTON also used both thisemailaddressand this phone numberto communicate

with CHS 3inconnectionwith thefraudulentPPP loan forEmeraldJade).
24. O n or about June 2,2020,a PPP Ioan application package on behalfof Em erald

Jade waselectronically submitted to Bank 3 through Bank Processor 1. Internetprotocol(tûlP'')
session records from Bank Processor 1 forthe loan application show thata com puterw ith an IP

address(ending in 170)associated with CHS 2'sresidence in Broward County,Florida,Iogged
into the Em erald Jade loan accounton oraboutJune 2,2020. The session records also revealfour

additionalIoginsby the same IP address(ending in 170)on the sam eday,and two loginson or

3 DEN TON updated her records w ith the California Departm ent of M otor Vehicles in
August2020. ,the updated address on DENTO N 'S Departm ent of M otor Vehicles record is the
address in w hich D EN TON currently resides in Eastvale,California.

Page8 of 14
aboutJune3,2020byacomputerwithanIPaddress(endingin l52)associatedwithDENTON'S
residence. The session recordsshow three additionalloginsby the IP address (ending in l52)
associated w ith DEN TON 'S residence. Records for DEN TON 'S accountatBank 7 show that

DEN TON also used the IP addressending in l52 to accessD EN TON 'Saccountonline and conduct

online transfers.

Theloanapplicationpackageincluded,amongotherdocuments:(1)fourpurported
Forms94lforeachquarterof20l9 inthenameofEmeraldJade;(2)apurportedcompany bank
statementforEmeraldJade from Bank 7;and(3)aBorrowerApplication Form fora PPP loan
requestof$49l,310forEmeraldJadebaseduponapurportedaveragemonthlypayrollof$196,524

for24 employees(thettPPP Application Form'').
26. The purported Form s 941 subm itted w ith Em erald Jade's PPP loan application

package show quarterly payroll of over $589,574.04 each quarter,for 24 employees. That
quarterly payrollGgure yielded the PPP loan application's iûAverage M onthly Payroll''tsgure of

$196,524,whichdeterminedthe$491,310amountoftheloan.EachForm 94lwassigned by hand
w ith the nam e tûcindi Denton''as the com pany owner,and also Iisted tûcindiDenton''as the

com pany'sdesignee and asa ttpaid Preparer,''although DENTON isnota paid tax preparer.4

27. The purported Form s 94l subm itted w ith Em erald Jade's PPP loan application

package follow the sam e styleand pattern,including the indiciaoffraud,as the m any otherForms

941 thatCHS 2 acknowledged thathe helped create and subm it in the course of the schem e,as

4 CHS 2 adm itted during interview sw ith Iaw enforcem entthatCHS 2 signed m any ofthe
Form s941included in the PPP applications.The signature on Em erald Jade'sForm s94l included
w ith its PPP applicationsresemblesa signature thatCH S 2 identifsed asonethatCHS 2 forged.

Page9 of 14
described above.s The purported Form s 94l included the contactinform ation and identifiersthat

D EN TON had included on the Stintake form ''thatD EN TON em ailed to CHS 3.

28. M oreover,IRS records show thatEmerald Jade did not,in fact,t5le any Form s 94l

for any quarter of 20l9 or the Grst quarter of 2020. Likew ise, State of California Labor and

W orkforce Developm entA gency recordsdemonstrate thatEmerald Jade has notfiled to w ithhold

Californiaemploymenttaxesfor2018,2019,orQuarters land 2of2020.
The purported com pany bank statem ent for Em erald Jade subm itted with its PPP

loan application package,which was subm itted in electronic form atas a PD F,is a clearforgery.

First,itpurports to be a February 2020 bank statem entfrom Bank 7;however,based upon bank

recordsfrom Bank 7,the statem entforthe actualEm erald Jade Bank 7 accountis dissim ilarfrom

the PDF statem entattached to the PPP application. Second,according to the PDF file ktproperties,''

the February 2020 statem entw ascreated using tIPD FFILLER,''a program used to editelectronic

PDF files,and wasûlm odified using i'
I-ext.'e The m etadata showsthe f5le w as created on orabout

M ay 30,2020 and m odified on oraboutJune 2,2020. Third,the statem entis a recycled version

A s noted above,DENTON was listed as both ow nerand paid preparer. Dozensofother
Form s 94l subm itted in this schem e evidence the sam e error. CH S 2 has adm itted that these
documentsshare thatfeature because hem isunderstood the form,and he (orsomeonefollowing
his instructions) prepared the Forms 94l at issue. The content of the form s also indicate
falsification. Em erald Jade subm itted fouridentical94 1s the form s include wage fsguresthatare
identicaldowntothepenny inreported figures).They also evidenceapatternofpayrollspending
thatislikely false:each ofthe quarters showssignificantincreasesfrom thefirstto second to third
m onth ofthe quarter. Foreach identicalform ,the sam e figuresare reported forthe tax liability
incurred in the firstm onth ofeach quarter,the sam e figure forthe second m onth ofeach quarter
(increased substantially from thefirstmonth),andthesamefsgureforthethirdmonthofthequarter
(increasedsubstantiallyfrom thesecondmonth).Theresultisthatthecompanyreportsaperfectly
repeating cycle ofascending payrollcostsw ithin each quarter. CH S 2 hasexplained thatthiswas
due to a form ula he used,allocating differentpercentages ofthe quarterly payrolltax liability to
each month ofeach quarter.

Page 10 of 14
ofthe sam e falsified Bank 7 statem entused in other fraudulentapplications subm itted as pal'
tof

thisschem e.
30. The PPP Application Form required the borrow er to electronically initialand/or

sign (via Docusign,asexplained below)anumberofiicertifications,''including:(1)thatthe
applicant business was in operation on February 15,2020 and had em ployees to whom itpaid

salaries/payrolltaxesorpaid independentcontractors,asreported on Formts)1099;(2)thatthe
funds would be used to retain workers,m aintain payroll,orm ake m olgage/interest/lease/utility

paym entsas specifsed by the PPP ruleand thatunauthorized use could resultin chargesforfraud'
,

and (3)thatthe information provided in theapplication,including in supporting documents,was
bltrue and accurate in alI m aterial respects,'' and that m aking false statem ents could result in

crim inalcharges.
Based on the false and fraudulent representations m ade in the PPP Application

Form and supporting docum ents,Bank Processorlapproved the PPP loan application forEmerald

Jade.Asexplained ingreaterdetailbelow,Bank3 wiredapproximately$49l,3l0in loanproceeds

to Em erald Jade on oraboutJune 3,2020.

Records Show thatD EN TON Viewed :la# Sikm ed thePpp Alm lication Form
In connection w ith this investigation, law enforcem ent obtained records from

Docusignpursuantto l8U.S.C.j2703(d).Basedonareview oftherecords,law enforcement
believesDENTON signed the PPP application forEm erald Jade using D ocusign.

Specifically,the Docusign records show that,on June 2,2020,at 9:42:25 a.m .,

Bank Processor lsentthe PPP A pplication Form to theDocusign useriecindiD enton''atthe em ail

addressilcindi@ emeraldjadesolutions.com.''6 As mentioned above,DENTON used the email

6 Based on inform ation provided by CHS 3,the application wascreated by CHS 2.

Page 11 of 14
addressiscindi@ emeraldjadesolutions.com''to communicatewith CHS 3 inconnection withthe
fraudulentPPP Ioan for Em erald Jade.

34. Based upon these records from Docusign,itis reasonable to inferthatD EN TON

view ed the PPP Application Form on oraboutJune 2,2020 at9:42:43 a.m .,and D EN TON signed

the PPP Application Form on oraboutJtlnc 2,2020 at9:43:33 a.m .

Records Conflrm DENTON 'SReeeiptofthePPP Loan and FurtherDemonstrateDEN TON 'S
Knowinz Participation in the Fraud
As partof its investigation, law enforcem ent obtained bank records as well as

com m unicationsbetw een CH S 3 and D ENTON,including textm essages and em ailsprovided by

CHS 3 to law enforcement.
36. Bank records show thatEm erald Jade had an accountatBank 7 ending in *7366

(tûBank7 *7366':).Customerinformation fortheBank 7*7366accountshowsthatDENTON was
the sole signatory on the accountand identifies DEN TON 'S title as 'isecretary.'' Based on m y

review,the signature on thisaccountappears to m atch the signatureon the PPP loan application.

On oraboutJune 2,2020,CHS 3 sentatextmessage rem inding DEN TON to check

her em ail and DEN TON responded, 'tW iII do. Thank you.'' Later that day, from the

cindi@emeraldjadesolutions.com account,DENTON forwarded an emailto CHS 3 with the
subject,kiYourPPP fundsareontheway.''
38. The nextday,the Bank 7 *7366 account received via bank w ire approxim ately

$491,310 in loan proceeds from Bank 3 as a resultof Emerald Jade's fraudulent PPP loan

application.

39. On oraboutJune 4,2020,DENTON wired an approxim ately $98,262 kickback
paym ent,which equaled approxim ately 20 percentofthe proceeds of Em erald Jade's PPP Ioan,

from the Bank 7 *7366 accountto an accountatBank 7 controlled by CH S 3. Tw o weeks Iater,

Page 12 of14
on oraboutJune 16,2020,D EN TON sentCHS 3 an invoice purporting to show thatEm erald Jade

owed CHS 3$98,000 forconsulting services.CHS 3 hastoldlaw enforcementthatDENTON told
him he needed to sign the docum entand thathe recognizes the num berasthe kickback paym ent

thatDENTON m adeto him forthe loan.

40. Based on m y rcview ofthe bank records discusscd above,DEN TON has spenta

significantam ountofthe rem aining PPP Ioan proceeds. Betw een on oraboutJune4,2020 and on

oraboutJune 26,2020,in addition to the w ire to CH S 3,D ENTON sentadditionalw irestotaling

approximately $175,860,including a $150,000 wire to a personalchecking accountatBank 7
ending in 6999. M oreover,itdoes notappearthatany ofthe proceedsofthe PPP Ioan were used

for Iegitim ate business expenses or payroll related expenditures to any em ployee other than

DEN TON herself.

Law enforcem entobserved video surveillance from Bank 7 thatshows D ENTON

conducting cash w ithdraw als ata Bank 7 location on oraboutJune 4,2020 and June 8,2020.The

cash withdrawalswereeach intheamountof$9,900.

4 Recorded Callwith CHS 3 ConfirmsDENTON 'SKnowinz Particilmtion in theFraud
,

42. A s pal4 ofthe investigation,and at law enforcem ent's direction,CH S 3 placed a

controlled callto D EN TON on or aboutJuly 2,2020,by calling the num ber he had previously

used to textm essage w ith DENTON. During thecall,D EN TON said thatDEN TON used the PPP

loan fundsto pay itbills,''including çicreditcardsand carsand rentsand aIIthatkind ofstuff.'' CHS

3 asked D EN TON how m any em ployees were included on Em erald Jade's PPP application.

DEN TON stated,ikW e only have one paid em ployee.'- CHS 3 responded,ç1Iunderstand thatbut

you know thatwe bullshitted and said you had,like,20,so you gotta help me here.'' DENTON

replied,$ûOh,God .. .I don't know how to do that,l don't know w hat you w ant m e to do.''

Page 13 of14
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HONORA LE PATRICK M .HU NT
UN ITED STATES M AGISTRATE JUDGE

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