Criminal Complaint — Christian Johnson (Western District of New York)
Summary
Criminal complaint filed 01/29/21 in the Western District of New York, Case No. 21-mj-1054, against Christian Johnson. It charges that between on or about April 16, 2020, and on or about May 21, 2020, in the County of Erie, Johnson executed or attempted to execute a scheme to defraud Bank 1 and Bank 2, and made a false statement to Bank 1 and Bank 2 on an application or loan. A wire fraud count covers on or about April 16, 2020, through on or about May 27, 2020, and names Lender 1 and Financial Services Companies 1, 2, and 3. The complaint states that it is based on facts continued on an attached sheet and was sworn to telephonically, and the text closes with a request that supporting papers be sealed until further order of the Court.
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“Criminal Complaint — Christian Johnson (Western District of New York).”
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Case 1:21-mj-01054-JJM Document 1 Filed 01/29/21 Page 1 of 21
AO 91 (Rev. 02/09) Criminal Complaint
United States District Court
for the
Western District ofNew York
United States ofAmerica
Case No. 21-mj-1054
v.
CHRISTIAN D. JOHNSON
Defendant
CRIMINAL COMPLAINT
I, the complainant in this case, state that the following is true to the best of my knowledge and belief.
Between on or about April 16, 2020, and on or about May 21, 2020, in the County of Erie, in the Western
District of New York and elsewhere, the defendant, CHRISTIAN D. JOHNSON, did knowingly, willfully, and
unlawfully execute, or attempt to execute, a scheme or artifice to defraud a financial institution, or to obtain any of
the moneys, funds, credits, assets, securities, or other property owned by, or under the custody or control of, Bank 1
and Bank 2, by means of false or fraudulent pretenses, representations, or promises.
All in violation of Title 18, United States Code, Section 1344.
Between on or about April 16, 2020, and on or about May 27, 2020, in the County of Erie, in the Western
District ofNew York and elsewhere, the defendant, CHRISTIAN D. JOHNSON, having devised a scheme or artifice
to defraud Lender 1, Financial Services Company 1, Financial Services Company 2, and Financial Services Company
3, or for obtaining money or property of Lender 1, Financial Services Company 1, Financial Services Company 2,
and Financial Services Company 3, by means of materially false and fraudulent pretenses, representations, and
promises, and for the purpose of executing such scheme and artifice, did transmit, and did cause to be transmitted, by
means of wire communications in interstate and foreign commerce, writings, signs, signals, pictures, and sounds.
All in violation of Title 18, United States Code, Section 1343.
Between on or about April 16, 2020, and on or about May 21, 2020, in the County of Erie, in the Western
District of New York and elsewhere, the defendant, CHRISTIAN D. JOHNSON, did knowingly make a false
statement or report to Bank 1 and Bank 2, upon an application or loan, for the purpose of influencing in any way the
action of Bank 1 and Bank 2.
All in violation of Title 18, United States Code, Section 1014.
Case 1:21-mj-01054-JJM Document 1 Filed 01/29/21 Page 2 of 21
This Criminal Complaint is based on these facts:
181 Continued on the attached sheet.
JEFF G. THOMSON
SPECIAL AGENT
FEDERAL DEPOSIT INSURANCE CORPORATION
Printed name and title
Sworn to telephonically.
Date: January 29 , 2021
Judge's signature
HONORABLE JEREMIAH J. McCARTHY
City and State: Buffalo, New York UNITED STATES MAGISTRATE JUDGE
Printed name and title
2
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REQUEST FOR SEALING
64. I further request that the Court order that all papers in support of this complaint,
including the affidavit and arrest warrant, be sealed until further order of the Court. These
documents discuss an ongoing criminal investigation that is not public. Although the target of the
investigation likely is aware generally of the investigation, he does not know any details of the
investigation or investigative steps being undertaken to obtain documents and information relating
to the PPP loan applications at issue. Accordingly, there is good cause to seal these documents
because their premature disclosure may increase the likelihood that the target flees/continues flight
from prosecution, destroys or tampers with physical or electronic evidence, changes patterns of
behavior, notifies confederates, or otherwise seriously jeopardizes the investigation.
Special Agent
FDIC Office oflnspector General
Sworn to telephonically
January 29, 2021.
HONORABLE JEREMIAH J. McCARTHY
UNITED STATES MAGISTRATE JUDGE
19
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