Criminal Complaint — No. 2:26-mj-30001 (Dkt. 1, E.D. Mich.)

Summary

A criminal complaint and affidavit, filed under seal January 5, 2026 as ECF No. 1 in Case 2:26-mj-30001, U.S. District Court for the Eastern District of Michigan, against Peter Valente and Angela Hilal Toma. It charges both with conspiracy to commit wire fraud under 18 U.S.C. § 1349, and Valente alone with obstruction of justice under 18 U.S.C. § 1503, for conduct from July 2020 through October 2023 in Wayne and Oakland counties. The affidavit of Special Agent Victor VanMeerbeeck alleges that Toma obtained $2,609,210 in PPP loans for three businesses that were never operational, filed at least five EIDL applications that yielded a $4,000.00 advance, and moved over $1,000,000 to accounts Valente controlled. It alleges that Valente, in three voluntary interviews, falsely denied knowing of the loans until they were complete, which the affiant says text messages contradict.

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Full text

Case 2:26-mj-30001-DUTY ECF No.AUSA:
1, PageID.48 Filed 01/05/26 Telephone:
Kenton C. Welkener Page 1 of 35269-4796
(313)
AO 91 (Rev. ) Criminal Complaint Special Agent: Victor VanMeerbeeck Telephone: (602) 768-7086

UNITED STATES DISTRICT COURT
for the
Eastern District of Michigan

United States of America
v. Case: 2:26−mj−30001
Assigned To : Unassigned
D-1 Peter Valente Case No. Assign. Date : 1/5/2026
D-2 Angela Hilal Toma
Description: CMP USA V. VALENTE
ET AL (DJ)

CRIMINAL COMPLAINT

I, the complainant in this case, state that the following is true to the best of my knowledge and belief.

On or about the date(s) of July 2020 through October 2023 in the county of Wayne and Oakland in the
Eastern District of Michigan , the defendant(s) violated:
Code Section Offense Description
18 U.S.C. § 1349 Conspiracy to Commit Wire Fraud
18 U.S.C. § 1503 Obstruction of Justice

This criminal complaint is based on these facts:
see attached affidavit.

✔ Continued on the attached sheet.

Complainant’s signature

Victor VanMeerbeeck, Special Agent (HSI)
Printed name and title
Sworn to before me and signed in my presence
DQGRUE\UHOLDEOHHOHFWURQLFPHDQV

Date:
January 5, 2026 Judge’s signature

City and state: Detroit, Michigan Hon. Kimberly G. Altman, United States Magistrate Judge
Printed name and title
Case 2:26-mj-30001-DUTY ECF No. 1, PageID.49 Filed 01/05/26 Page 2 of 35

IN THE UNITED STATES DISTRICT COURT
FOR THE EASTERN DISTRICT OF MICHIGAN
SOUTHERN DIVISION

D-1 PETER VALENTE, and Case No.
D-2 ANGELA HILAL TOMA,

Defendants.

Filed Under Seal

AFFIDAVIT IN SUPPORT OF
A CRIMINAL COMPLAINT

I, Victor VanMeerbeeck, being first duly sworn, hereby depose and state as

follows:

I. Executive Summary

1. I make this affidavit in support of a criminal complaint and arrest

warrants against both PETER VALENTE and ANGELA HILAL TOMA for

violating 18 U.S.C. § 1349 (Conspiracy to Commit Wire Fraud) and against

PETER VALENTE alone for violating 18 U.S.C. § 1503 (Obstruction of Justice).

VALENTE and TOMA—who during the periods referenced in this affidavit were

husband and wife—collaborated to fraudulently obtain $2,609,210 from the

Paycheck Protection Program. After learning of the investigation, VALENTE

obstructed justice by approaching the Government and falsely telling this affiant

that he did not learn about the scheme until it was complete, and that TOMA had
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obtained VALENTE’s business records to alter for use in the scheme by hacking

VALENTE’s phone.

2. An introduction and agent background are in ¶¶ 3-5. Applicable

statutes are in ¶¶ 6-7. Background on the Paycheck Protection Program and

Economic Injury Disaster Loan Program is at ¶¶ 12-19. A summary of key

investigative findings is in ¶¶ 20-22, with more detail in the paragraphs that follow.

These include VALENTE’s statements to this affiant implicating his wife but not

himself, and the text messages demonstrating the material falsity of many of his

statements, in ¶¶ 67-105.

II. Introduction and Agent Background

3. I have been a Special Agent with the Department of Homeland

Security, Immigration and Customs Enforcement, Homeland Security

Investigations since November of 2009. I was a member of the High Intensity

Drug Trafficking Area (HIDTA) Task Force operating out of the Phoenix, Arizona

Office of Investigations for eight (8) years. I am currently assigned to the financial

group in Detroit, MI investigating violations of federal law. I am a graduate of the

Criminal Investigator Training Program and the Immigration and Customs

Enforcement Special Agent Training Program at the Federal Law Enforcement

Training Center at Glynco, Georgia. I am a graduate of Michigan State University
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with a Bachelor of Arts Degree in Finance.

4. The information contained in this affidavit is based upon my personal

knowledge, training and experience, as well as the combined knowledge, training

and experience of other law enforcement officers and agents with whom I have

had discussions, and information obtained from witnesses, other special agents,

criminal analysts, documents, and government databases.

5. This affidavit is submitted for the limited purpose of securing a

criminal complaint and arrest warrants; therefore, this affidavit does not contain

every fact that I have learned during the investigation. I have only set forth the

facts necessary to establish probable cause to believe that Defendants violated the

statutes identified above.

III. Applicable Statutes

6. 18 U.S.C. § 1349 (Attempt and Conspiracy) criminalizes attempting

or conspiring to commit any offenses under Chapter 63 of 18 U.S.C., including a

violation of 18 U.S.C. § 1343 (Wire Fraud). 18 U.S.C. §1343 criminalizes schemes

or artifices to defraud, or obtaining money or property by means of false or

fraudulent pretenses, representations, or promises, when for the purpose of

executing the scheme, the person transmits, or causes to be transmitted, any

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writings, signs, signals, pictures, or sounds by means of wire communication in

interstate commerce.

7. 18 U.S.C. § 1503 (Obstruction of Justice) criminalizes, inter alia,

corruptly influencing, obstructing, impeding, or endeavoring to influence, obstruct,

or impede, the due administration of justice. It requires proof of three elements:

“(1) there was a judicial proceeding; (2) the defendant had knowledge or notice of

the pending proceeding; and (3) the defendant acted corruptly with the intent of

influencing, obstructing, or impeding the proceeding in the due administration of

justice.” United States v. Collis, 128 F.3d 313, 318 (6th Cir. 1997).

8. Based on the facts as set forth in this affidavit, there is probable cause

to believe that PETER VALENTE and ANGELA TOMA conspired to submit false

Payroll Protection Program (PPP) loan applications, and false Economic Injury

Disaster Loan (EIDL) applications. In doing so, ANGELA TOMA and PETER

VALENTE conspired to obtain money or property by means of false and

fraudulent pretenses and representations, facilitated using interstate wire

communications.

9. Furthermore, as detailed below, PETER VALENTE—with

knowledge of the ongoing investigation—conducted three voluntary interviews

with federal investigators, and in each interview falsely asserted and maintained
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that TOMA committed PPP fraud on her own, without his knowledge or

collaboration. This conduct impeded and delayed the investigation.

IV. Defendants

10. PETER VALENTE is a 52-year-old male, believed to reside in West

Bloomfield, Michigan.

11. ANGELA TOMA is a 45-year-old female, believed to reside in

Southfield, Michigan.

V. The Paycheck Protection Program

12. The Coronavirus Aid, Relief, and Economic Security (CARES) Act

was a federal law enacted in or around March 2020 and designed to provide

emergency financial assistance to the millions of Americans suffering the

economic effects caused by the COVID-19 pandemic. One source of relief

provided by the CARES Act was the authorization of forgivable loans to small

businesses for job retention and certain other expenses through a program referred

to as the Paycheck Protection Program (PPP). In or around April 2020, Congress

authorized over $300 billion in additional PPP funding.

13. The PPP is administered by the United States Small Business

Administration (SBA). In order to obtain a PPP loan, a qualifying business must

submit a PPP loan application, which is signed by an authorized representative of
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the business. The PPP loan application requires the business (through its authorized

representative) to acknowledge the program rules and make certain affirmative

certifications to be eligible to obtain the PPP loan. The PPP loan applications

include an SBA Borrower Application Form. The form includes a certifications and

authorizations portion. In the PPP loan application, the small business (through its

authorized representative) must state, among other things, its average monthly

payroll expenses and number of employees. These figures are used to calculate the

amount of money the small business is eligible to receive under the PPP. In

addition, businesses applying for a PPP loan must provide documentation showing

their payroll expenses.

14. A PPP loan application must be processed by a participating lender. If

a PPP loan application is approved, the participating lender funds the PPP loan

using its own monies, which are 100% guaranteed by the SBA. Data from the

application, including information about the borrower, the total amount of the loan,

and the listed number of employees, is transmitted by the lender to the SBA in the

course of processing the loan.

15. PPP loan proceeds must be used by the business on certain permissible

expenses, such as: payroll costs, interest on mortgages, rent, and utilities. The PPP

allows the interest and principal on the PPP loan to be entirely forgiven if the
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business spends the loan proceeds on these expense items within a designated

period of time after receiving the proceeds and uses a certain amount of the PPP

loan proceeds on payroll expenses.

VI. The Economic Injury Disaster Loan Program

16. The Economic Injury Disaster Loan (“EIDL”) program is an SBA

program that provides low-interest financing to small businesses, renters, and

homeowners in regions affected by declared disasters.

17. The CARES Act authorized the SBA to provide EIDLs to eligible

small businesses experiencing substantial financial disruption due to the COVID-

19 pandemic. In addition, the CARES Act authorized the SBA to issue advances

of up to $10,000 to small businesses within three days of applying for an EIDL.

The amount of the advance is determined by the number of employees the applicant

certifies having. The advances do not have to be repaid.

18. In order to obtain an EIDL and advance, a qualifying business must

apply to the SBA and provide information about its operations, such as the

number of employees, gross revenues for the 12-month period preceding the

disaster, and cost of goods sold in the 12-month period preceding the disaster. In

the case of EIDLs for COVID-19 relief, the 12-month period was that preceding

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January 31, 2020. The applicant must also certify that all of the information in the

application is true and correct to the best of the applicant’s knowledge.

19. EIDL applications are submitted directly to the SBA and processed

by the agency with support from a government contractor, Rapid Finance. The

amount of the loan, if the application is approved, is determined based, in part, on

the information provided in the application about employment, revenue, and cost

of goods, as described above. Any funds issued under an EIDL or advance are

issued directly by the SBA. EIDL funds can be used for payroll expenses, sick

leave, production costs, and business obligations, such as debts, rent, and

mortgage payments. If the applicant also obtains a loan under the Paycheck

Protection Program, the EIDL funds cannot be used for the same purpose as the

Paycheck Protection Program funds.

VII. Summary of the Investigation

20. PPP Fraud: In October 2020, Special Agents of HSI initiated an

investigation into ANGELA TOMA and discovered TOMA was the recipient of

SBA PPP loans for three separate businesses – Detroits Red Light District 2 LLC,

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Building Detroit Group LLC, and DF Worldwide.1 Through February of 2021,

TOMA had received $2,609,210 in funds for these three businesses from the SBA.

Investigation reveals that fraudulent documents were provided with the

electronically submitted SBA loan applications, and the SBA funds were not used

as required by the PPP program. In short, the businesses were never operational,

and the financial figures and documents provided in support of the PPP

applications were fabricated.

21. EIDL Fraud: In addition, between April 2020 and August 2020,

Toma submitted at least five EIDL loan applications to the SBA in the names of

four business entities: Detroits Red Light District 2 LLC, Giving Back 2 Detroit,

Angela Hilal Toma Corporation, and Building Detroit Group LLC.

22. As in the PPP context, these businesses were never operational, and

the financial figures and documents provided in support of the EIDL applications

were fabricated. Although most of these applications were declined, the SBA did

give a $4,000.00 EIDL advance into the account for Detroit’s Red Light District 2.

Your affiant has seen DF Worldwide referred to with a variety of labels, but “DF
1

Worldwide” was how it was labeled in the PPP application.

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23. Text messages between TOMA and VALENTE revealed that

VALENTE was aware of the fraudulent scheme, actively assisted TOMA in

preparing and submitting the fraudulent applications, and directed TOMA to

transfer over $1,000,000 of the ill-gotten gains to bank accounts under his control.

Bank records show that VALENTE used the fraudulently obtained funds to pay off

debts, among other expenses. TOMA primarily used her portion of the proceeds

on personal living expenses.

VIII. Probable Cause

Recipients of PPP Funds

24. Your affiant reviewed public records which indicated that all three

businesses that applied for PPP funds had the same listed resident agent, ANGELA

TOMA. Granite Fabricators Building Detroit Group LLC was organized on or

about August 23, 2017, and its name was changed to Building Detroit Group LLC

on August 18, 2020. Detroits Red Light District 2 LLC was organized on June 9,

2015, and DF Worldwide was incorporated on November 2, 2018.

25. Using an open-source website, an HSI Detroit Criminal Analyst

reviewed publicly available loan information relating to the PPP. A review of this

information revealed that DF Worldwide and Detroits Red Light District 2 LLC

both had approved loans using the same reported address of 26400 W. 8 Mile
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Road, Southfield, MI 48033. Building Detroit Group LLC also had approved

loans with a reported address 26530 W. 8 Mile Road, Southfield, MI 48033.

Physical surveillance of both locations revealed that 26400 W. 8 Mile Road is a

business, Safe Keeping Self Storage, which rents out individual offices within the

building, while 26530 W. 8 Mile Road is a commercial building with a sign that

reads “Granite Source of Michigan.”

26. A request to the state of Michigan revealed that there were no state

employment records or quarterly wages for any of the three businesses.

27. Your affiant reviewed federal tax information and determined that

the entities referenced in paragraph 12 – Detroits Red Light District 2 LLC,

Building Detroit Group LLC, and DF Worldwide – did not file federal tax returns

for tax years 2018-2021.

28. Your Affiant reviewed records received from Bank of America

regarding bank accounts belonging to DF Worldwide, Detroits Red Light District

2 LLC, and Building Detroit Group LLC. Analysis of the credit transactions from

the statements identified $2,610,660 in funds received from outside sources with

$2,609,210 (99.94%) stemming from approved PPP loans.

Use of PPP Funds

29. Analysis of the debit transactions did not identify any formal payroll
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structure present in most of these business bank accounts. Most of the funds were

sent to external business accounts, external individual accounts, or withdrawn as

cash. Approximately $1,099,675 of the funds leaving the accounts were paid to

three recipients: CRW Inc., Granite Fabricators, and PETER VALENTE.

VALENTE was identified as ANGELA TOMA’s husband and was linked to both

CRW Inc. and Granite Fabricators.

30. An examination of the cleared check images revealed that the memo

lines referenced “payroll” or “payroll reimbursement” on all but one of the

handwritten checks, despite the recipient being Valente and his businesses. The

remaining check, written to Granite Fabricators, referenced “rent”. All the written

checks to CRW, Granite Fabricators, and VALENTE were deposited at various Fifth

Third Bank accounts, and VALENTE appeared to be the endorser of all the checks.

There were three checks made out to CRW Inc. totaling $35,100.00 that referenced

April 2020 payroll, and four checks made out to Granite Fabricators totaling

$50,250.00 that referenced April 2020 payroll. There were five checks to Granite

Fabricators totaling $78,900.00 that referenced May payroll. Several of the checks

had multiple months written on the memo line. All the checks to Granite Fabricators

and CRW Inc. were written in round dollar amounts.

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31. The check written out to VALENTE, in the amount of $40,000, stated

“Payroll reimbursement + gift” on the memo line.

32. There were two checks written to Individual 1, each for $20,000, that

referenced payroll for either April 2020 or May 2020. Individual 1 did not receive

additional checks for other months. Individual 1 has been identified as TOMA’s

sister.

33. There was one illegible check that appeared to have been deposited

into a Bank of America account for the Bright Horizon’s Children Center, doing

business as West Bloomfield Campus. Open-source research identified this

business as child care/preschool located at 2965 Walnut Lake Road, West

Bloomfield, MI 48323.

34. Approximately $207,949.07 was spent on apparent living expenses:

purchases for restaurants, e- commerce businesses, clothing stores, grocery stores,

furniture stores, gas stations, ride-share services, hotels, and airlines. For example,

there were 219 transactions conducted with the food delivery service, Door Dash,

totaling $20,529.35.

35. The signature cards provided by Bank of America for the business

accounts listed ANGELA TOMA as the account owner. Some additional details

on these accounts:
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• Account #XXXXXXXX8386: Building Detroit Group LLC, EIN
XXXXX4004. The signature card was dated July 18, 2020. This
account received $616,800.00 from SBA on August 17, 2020;
received another $616,800.00 from SBA on March 9, 2021.
• Account #XXXXXXXX8470: DF Worldwide, EIN XXXXX0028.
The signature card was dated July 18, 2020. This account received
$266,670.00 from SBA on August 18, 2020; received another
$266,670.00 from SBA on March 23, 2021.
• Account #XXXXXXXX0406: Detroits Red Light District 2 LLC,
EIN XXXXX1874. The signature card was dated July 24, 2020. This
account received $421,030.00 from SBA on August 25, 2020;
received another $421,240.00 from SBA on February 17, 2021.
36. Bank of America closed the accounts in June 2021 with

approximately $910,103.02 remaining across the seven accounts.

37. Your affiant reviewed records received from Fifth Third Bank

regarding bank accounts and credit card accounts belonging to Granite Fabricators

& Tile Center LLC, CRW Inc., Detroits Red Light District 2 LLC, PETER

VALENTE, and ANGELA TOMA. VALENTE, by himself, was identified as the

authorized signer for CRW Inc. and Granite Fabricators.

38. The Fifth Third Bank records included information on Essential

Checking Account XXXXXX9733, belonging to VALENTE, to include

statements, deposit images, and a signature card. This account had an open date

of August 11, 2020. A summary of the incoming transactions showed that a wire

was received from Bank of America account #XXXXXXXX6666, owned by
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Building Detroit Group LLC with TOMA as the sole owner, ten (10) days after

the account was opened in the amount of $75,000.00. On August 28, 2021, a

check for $40,000.00 was received from Bank of America account

#XXXXXXXX0406, owned by TOMA/ Detroits Red Light District 2 LLC, with

the note “Payroll Reimbursement + Gift”. On January 4, 2021, a check for

$50,000.00 was received from Granite Source of Michigan with the note “Loan

paid back”.

39. These two checks and the wire originated from TOMA’s accounts

that were funded with SBA loans. A summary of the outgoing transactions from

Bank of America account #XXXXXXXX6666 revealed that a wire in the amount

of $141,760.46 was sent to Midwest Title LLC on November 3, 2020. Based on

open-source research, VALENTE and TOMA purchased 3865 Stonecrest Road,

West Bloomfield, MI, on November 3, 2020, for $610,000.00. An additional

$9,682.74 was paid to Lake Michigan Credit Union in two mortgage payments,

the first of which occurred approximately two months after the wire.

40. Your affiant reviewed records received from Midwest Title LLC

regarding the purchase of 3865 Stonecrest Road, West Bloomfield, MI. According

to the title records, VALENTE wired $141,760.46 from a Fifth Third Bank

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account on or around November 3, 2020, for the down payment to purchase 3865

Stonecrest Road for $610,000. The mortgage was obtained from Lake Michigan

Credit Union which stated this would be the new primary residence for

VALENTE and TOMA. TOMA was a signatory on the settlement statement but

not on the mortgage note.

Further Detail of Falsity in PPP Applications

41. Your affiant reviewed records received from Newtek Small Business

Finance LLC regarding the Payroll Protection Program (PPP) loan application

which TOMA submitted to them electronically.

42. A review of the documents provided by Newtek Small Business

Finance LLC revealed that TOMA provided quarterly federal tax filings for

Detroit Building Group LLC dating back to the 1st quarter of 2019 through the

1st quarter of 2020 to Newtek in support of the PPP loan application. Your affiant

communicated with the Internal Revenue Service (IRS) regarding any federal

business filings for TOMA’s companies and the IRS confirmed that there were no

tax returns for any of her businesses from 2018 to 2021. In addition, TOMA

supplied a monthly bank statement from Bank of America for business account

#XXXXXXXX8386 for February 2020. According to a previous subpoena

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response from Bank of America regarding this specific account number, the

account was not opened until months later: July 20, 2020. Your affiant sent a copy

of this February 2020 statement to a representative for Bank of America who

confirmed that the statement was fictitious.

43. The annual statements for 2018, 2019, and 2020 were all filed

through the State of Michigan Licensing and Regulatory Affairs on July 18, 2020,

with a Certificate of Restoration of Good Standing being issued on July 31, 2020.

In other words, Building Detroit Group LLC was not in good standing with the

State of Michigan for the two years prior to applying for PPP loans.

44. TOMA made the following certifications and authorizations on her

Newtek PPP application:

x All SBA loan proceeds will be used only for business-related purposes
as specified in the loan application and consistent with the Paycheck
Protection Program Rule.
x The Applicant was in operation on February 15, 2020, and had
employees for whom it paid salaries and payroll taxes or paid
independent contractors, as reported on Form(s) 1099-MISC.
x Current economic uncertainty makes this loan request necessary to
support the ongoing operations of the Applicant.
x The funds will be used to retain workers and maintain payroll or make
mortgage interest payments, lease payments, and utility payments, as
specified under the Paycheck Protection Program Rule; and that she
understand that if the funds are knowingly used for unauthorized

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purposes, the federal government may hold her legally liable, such as
for charges of fraud.
x The documentation provided by the Borrower to the Lender verifying
the number of full-time equivalent employees on the Borrower’s
payroll as well as the dollar amounts of payroll costs, covered mortgage
interest payments, covered rent payments, and covered utilities is
accurate in all respects.
x The information provided in this application and the information
provided in all supporting documents and forms is true and accurate in
all material respects. I understand that knowingly making a false
statement to obtain a guaranteed loan from SBA is punishable under
the law, including under 18 USC 1001 and 3571 by imprisonment of
not more than five years and/or a fine of up to $250,000; under 15 USC
645 by imprisonment of not more than two years and/or a fine of not
more than $5,000; and, if submitted to a federally insured institution,
under 18 USC 1014 by imprisonment of not more than thirty years
and/or a fine of not more than $1,000,000.
45. In August 2022, your affiant reviewed records received from Cache

Valley Bank regarding Payroll Protection Program (PPP) loan applications

submitted electronically by ANGELA TOMA for DF Worldwide and Detroits Red

Light District 2 LLC.

46. A review of all the quarterly wage reports provided on a spreadsheet

by TOMA to Cache Valley Bank revealed that the salary payouts were identical

for all four quarters of 2019 which signified that no employees received raises in

2019, worked overtime, or had unpaid time away from the company. These

quarterly reports were similar to the reports received from Newtek for PPP loans

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for Detroit Builders Group in that the wages were unchanged the whole year.

47. TOMA made the following certifications and authorizations

throughout her Cache Valley Bank PPP applications:

x The Applicant has certified to the Lender that the Applicant is eligible
under the Paycheck Protection Program Rules.
x The Applicant has certified to the Lender that (1) it was in operation on
February 15, 2020, has not permanently closed, and was either an
eligible self-employed individual, independent contractor, or sole
proprietorship with no employees or had employees for whom it paid
salaries and payroll taxes or paid independent contractors, as reported
on Form(s) 1099-MISC; (2) current economic uncertainty makes this
loan request necessary to support the ongoing operations of the
Applicant; (3) the funds will be used to retain workers and maintain
payroll, or make payments for mortgage interest, rent, utilities, covered
operations expenditures, covered property damage costs, covered
supplier costs, and covered worker protection expenditures; and (4) the
Applicant has not and will not receive another loan under the Paycheck
Protection Program, section 7(a)(36) of the Small Business Act (15
U.S.C. 636(a)(36)) (this does not include Paycheck Protection Program
second draw loans, section 7(a)(37) of the Small Business Act (15
U.S.C. 636(a)(37)).
48. In her communications with Cache Valley Bank, TOMA supplied a

bank statement purportedly from Bank of America for business account

#375022628470, DF Worldwide, for the month of June 2020. Bank of America

records for this specific account number show that the account was not opened

until July 2020. A Bank of America representative explained that the statements

were “forged,” and that the checks and transactions did not appear in Bank of

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America systems, and were not formatted in a manner used by Bank of America,

indicating that the bank statements may have come from a different bank, with

the headers changed to indicate Bank of America information.

49. In her communications with Cache Valley Bank, TOMA supplied a

bank statement from Bank of America for business account #XXXXXXXX0406,

Detroits Red Light District 2 LLC, for the month of February 2020. As previously

stated, Bank of America records for this specific account number show that the

account was not opened until July 2020. In addition, the account statement

summary does not add up, as the ending balance is about $80,000 too much.

50. In October 2022, your affiant reviewed records received from the

state of Michigan Unemployment Insurance Agency (UIA) related to ANGELA

TOMA and three businesses for which she applied for PPP loans. UIA provided

wage information for TOMA dating back to 2012. From 2013 to 2021, there is no

wage information for TOMA. There is no mention of Building Detroit Group

LLC, Detroits Red Light District 2 LLC, or DF Worldwide in TOMA’s history of

wages.

51. UIA also sent information regarding Building Detroit Group LLC,

Detroits Red Light District 2 LLC, and DF Worldwide. UIA reported that there

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were no records at all for any of these three businesses when queried by name or

employer identification number (EIN).

False EIDL Applications

52. On March 7, 2024, Special Agent (SA) Victor VanMeerbeeck

received a response to a request for loan applications and supporting

documentation from the SBA regarding Angela TOMA and Peter VALENTE. The

SBA provided six different applications originated by TOMA and/or VALENTE

and a couple communication files.

53. A review of the first EIDL application for DETROITS RED LIGHT

DISTRICT 2 submitted approximately April 8, 2020 showed that the email

address, angela_toma@aol.com, was used along with phone number 248-470-

1080. The SBA underwriter notated in the file that there was suspicious online

behavior and that the application was declined for fraud. There was also a

footnote stating, “Fraud found on related deal(s).”

54. TOMA stated that DETROITS RED LIGHT DISTRICT 2 LLC did

gross revenue of $890,000 for the twelve months prior to January 31, 2020 and

cost of good sold for the same time period was $740,000.

55. TOMA provided fraudulent bank statements for DETROITS RED

LIGHT DISTRICT 2 LLC to support the loan application. TOMA also supplied
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Case 2:26-mj-30001-DUTY ECF No. 1, PageID.70 Filed 01/05/26 Page 23 of 35

two false 2019 tax returns, one with the name BUILDING DETROIT GROUP on

it for the application. The other tax return was identical but had the name

DETROITS RED LIGHT DISTRICT 2 at the top. Based on previous information

received (see ROI #DT02OR22DT0005-008), there were no financial records

filed for any of TOMA’s companies. A closer look at the return showed that the

CPA firm listed as preparing the document, Rogers & Associates, did not exist at

the address, 26169 W. Warren St, Dearborn Heights, MI 48127. An open source

search did find a different CPA firm at the address, Moussawi & Associates CPA,

with a telephone number of 313-757-7831. The phone number listed for Rogers

& Associates was 313-667-7831. For the 2020 returns, Rogers and Associates

CPA was located at 26389 W. Warrant St, Dearborn Heights, MI 48127, an address

that does not exist. Rogers & Associates phone number was listed as 248-787-

7831 which comes back to Ashley Nemeth in Grand Blanc, MI.

56. To support the application, TOMA provided false tax transcripts,

which are fraudulent Internal Revenue Service (IRS) documents to prove that the

IRS received the filed tax returns. The SBA submitted a request for the 1120s for

years 2019, 2020, and 2021 on May 27, 2022 and received a response of “No

record of return filed” for all years.

57. On February 25, 2022, a declination letter was issued to TOMA for
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Case 2:26-mj-30001-DUTY ECF No. 1, PageID.71 Filed 01/05/26 Page 24 of 35

DETROITS RED LIGHT DISTRICT 2 for loan application 3303086685. The

letter stated that there were “one or more items that were reviewed that caused the

SBA to question the validity of certain information you submitted as part of your

application. This can occur as a result of a failed identity verification, high risk

IP address, or if a client device is associated with fraud.”

58. Two letters from Department of Treasury were in the file stating

Employer Identification Numbers (EIN) for Building Detroit Group and

DETROITS RLDS LLC. Both letters stated that TOMA must file Form 1065, the

business return for partnerships, and indicated that these forms had not been filed

for several years for these businesses.

59. On April 11, 2020, TOMA applied for an EIDL loan for GIVING

BACK 2 DETROIT. Based on the file provided, it appears that TOMA did not

provide any documentation in support of this application.

60. On April 12, 2020, TOMA applied for an EIDL loan for ANGELA

HILAL TOMA CORPORATION. Based on the file provided, it appears that

TOMA did not provide any documentation in support of this application.

61. On June 11, 2020, TOMA applied again for an EIDL loan for

ANGELA HILAL TOMA CORPORATION. Much of the data supplied for this

application was different from the first app to include company start date, gross
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Case 2:26-mj-30001-DUTY ECF No. 1, PageID.72 Filed 01/05/26 Page 25 of 35

revenue for previous twelve (12) months, and cost of goods sold for previous

twelve months (12). Based on the file provided, it appears that TOMA did not

provide any documentation in support of this application.

62. A review of the application submitted for BUILDING DETROIT

GROUP revealed that there were fraudulent documents submitted for support of

this loan application. Multiple fraudulent bank statements were provided as well

as a forged 2019 business tax return.

63. A review of the application submitted under DF WORLDWIDE

revealed that a fictitious business tax return for 2019 was submitted. An

application for an EIDL loan was submitted using VALENTE’s name on

approximately December 30, 2021. The signature was not VALENTE's however.

IP Address Information Linked to Valente and Toma

64. In October 2022, your affiant received information from Comcast

regarding subscriber information for several internet protocol (IP) addresses

responsible for originating TOMA’s PPP applications, including IP addresses

69.242.213.102 and 98.243.127.33.

65. Comcast stated that IP address 69.242.213.102 belongs to PETER

VALENTE Jr, for service at 219 Windward Ct., Detroit, MI 48207, a location that

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Case 2:26-mj-30001-DUTY ECF No. 1, PageID.73 Filed 01/05/26 Page 26 of 35

served as the primary residence for VALENTE and TOMA during the time period

in question. The following email user IDs are associated with this account –

“PETERVALENTE” and “fatinTOMA”. This IP Address was used to sign for the

Building Detroit Group’s PPP application through Newtek Small Business

Finance on August 13, 2020.

66. Comcast reported that IP address 98.243.127.33 belongs to “PETER

Valenti” for service at 21944 Murray Crescent Dr., Southfield, MI 48076, which

is the present address for TOMA’s mother. The email user ID associated with this

account is “fatinTOMA”. This IP address was used to sign for the second PPP

application for Building Detroit Group through Newtek Small Business Finance

on February 25, 2021.

Statements by VALENTE

67. During the course of the investigation, VALENTE spoke with your

affiant at the United States Attorney’s Office in Detroit, MI on three occasions:

May 2, 2023, August 17, 2023, and October 30, 2023. On each occasion,

VALENTE was aware of an ongoing federal investigation into PPP fraud.

68. In the initial conversation, May 2, 2023, VALENTE stated that

TOMA received PPP loans. VALENTE claimed that TOMA hacked his phone to

obtain Granite Fabricators bank statements, referring to a company owned by
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Case 2:26-mj-30001-DUTY ECF No. 1, PageID.74 Filed 01/05/26 Page 27 of 35

VALENTE. VALENTE further stated that TOMA edited these bank statements by

changing his company name to hers for multiple applications.

69. VALENTE stated that TOMA's companies have no revenue, no

employees, and no tax returns. VALENTE explained that TOMA's

companies exist only on paper.

70. VALENTE said TOMA received $1.3M on the first round of PPP

applications. VALENTE explained that he knows the above because he recovered

this information from TOMA’s email, ANGELA_TOMA@aol.com.

71. VALENTE stated that he believes $250,000 of the PPP funds were

used for purchasing his home, 3865 Stonecrest in West Bloomfield, MI.

VALENTE stated that TOMA told him that the money used for the down payment

was her inheritance from her grandfather. VALENTE said the home is worth

$1.2M and they owe $400,000.

72. VALENTE further stated TOMA possesses electronic devices,

including a cell phone and two iPads. VALENTE also indicated that he saw one

of the laptops belonging to TOMA at TOMA’s mother’s residence at 21944

Murray Crescent Dr., Southfield, MI 48076 with various documents in a bag in

the garage.

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73. At a 2nd interview with VALENTE on August 17, 2023, VALENTE

stated that he found out around July 2022 that the money given to him from

TOMA was from the PPP loans. He claimed to have found out about the PPP

loans when mail started arriving asking for repayment in 2022.

74. VALENTE was asked if he created, or had a hand in creating, the

fraudulent tax records to which he replied in the negative.

75. VALENTE said that TOMA's text messages would show her intent

to apply for all of these loans.

76. VALENTE stated that he has no knowledge about an application for

an Economic Injury Disaster Loan that was recovered during July 2023 search

warrants.

77. At a 3rd interview of VALENTE on October 30, 2023, when pressed

regarding the fact that over $1.2 million in fraudulent PPP funds went to accounts

controlled by VALENTE or to the purchase of the Stonecrest house, VALENTE

reiterated that TOMA told him that the funds to pay for the Stonecrest home were

an inheritance from her grandfather.

78. VALENTE stated that TOMA made a "clone" of his cell phone and

used it to obtain his bank statements.

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Case 2:26-mj-30001-DUTY ECF No. 1, PageID.76 Filed 01/05/26 Page 29 of 35

Messages Between Valente and Toma

79. However, text messages and supporting information indicate that

each of the above statements about VALENTE’s lack of knowledge and

collaboration in the PPP and EIDL fraud were false.

80. In July 2023, based on the information gathered throughout the

investigation, your affiant obtained and executed search warrants for 3865

Stonecrest Road, West Bloomfield, MI 48322, 21944 Murray Crescent Drive,

Southfield, MI 48076, and a Hummer vehicle located at the 3865 Stonecrest home

LQ-XO\RILQFDVHQXPEHUíPFí

81. More recently, on April 11, 2025, TOMA voluntarily provided access

to all data retrieved from the iPhone seized from TOMA during the search warrants

in 2023. Your affiant reviewed text conversations between Peter VALENTE and

Angela TOMA which were present on that iPhone.

82. A review of the conversation between TOMA’s iPhone and phone

number (248) 343-4859 revealed over 22,000 messages exchanged. An open

records search for (248) 343-4859 showed the phone number associated with

Granite Fabricators & Tile Center and its owner, VALENTE.

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Case 2:26-mj-30001-DUTY ECF No. 1, PageID.77 Filed 01/05/26 Page 30 of 35

83. In numerous messages, VALENTE and TOMA discuss the care of

their son, and bicker over finances. They also periodically collaborate on

applying for the PPP and EIDL loans, discuss the status of the applications,

celebrate receiving the funds, and discuss how to use the money.

84. On March 27, 2020, VALENTE texted TOMA “We are now about to

feel what it means to have no money”.

85. On March 31, 2020, TOMA tells VALENTE to “complete”

something for an SBA disaster loan. VALENTE responds that his partner applied

for one for their other business, CRW.

86. On April 7, 2020, VALENTE sent TOMA a link to

“https://covid19relief.sba.gov/#/” and says “This link gives initial $10k of loan.”

“Fill out this application under your company name. It's the sba 10000 forgivable.

You will need your ein number apply for both your companies.”

87. This belies VALENTE’S statements about having no knowledge of

an EIDL loan—he suggested that TOMA apply.

88. On April 8, 2020, TOMA in fact applied for an EIDL loan under the

company name DETROITS RED LIGHT DISTRICT 2 LLC. She stated the

company gross revenue as $890,000.

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89. On April 11, 2020, TOMA applied for an EIDL loan under the

company name GIVING BACK 2 DETROIT. She stated the company gross

revenue as $180,000.

90. On June 19, 2020, the SBA deposited a $4,000.00 EIDL advance

into the account for Detroit’s Red Light District 2.

91. On June 24, 2020, TOMA texted VALENTE a link to a realtor.com

listing for 3865 Stonecrest Road in West Bloomfield, MI.

92. In response on June 25, 2020, VALENTE said “We can't afford it.[]”

93. Later that day, VALENTE told TOMA “I am going to assume that

since you got uia [unemployment] and sba emergency money I don't need to give

you money for a while correct.”

94. On June 26, 2020, TOMA said to VALENTE “Please send me April

and May bank statement. 1live oak bank is willing to do Sba loan to consolidate

and working capital. It’s a bank it’s not a broker sent it to me as soon as possible

please[.]” VALENTE responds “Send me their info I will deal with them[.]”

95. This belies VALENTE’s statement that TOMA hacked his phone to

obtain his business records to alter for the scheme. Rather, he sent them to her on

purpose.

96. On June 29, 2020, TOMA asked VALENTE to “Please send me April,
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Case 2:26-mj-30001-DUTY ECF No. 1, PageID.79 Filed 01/05/26 Page 32 of 35

May and Download June today bank statement. And P&L for 2019.I need them

immediately I will not let anybody run your credit or do anything without you

speaking to them but I have two people that I was speaking to that sent you

information . Their direct lenders are not brokers with Live Oak Bank[.]”

97. In a follow-up text the same day, TOMA said “April statement May

statement June to date and p and l 2019[.]”2 VALENTE responded “I sent you

email.”

98. Again, this belies VALENTE’s statement that TOMA hacked his

phone to obtain his business records to alter for the scheme. Rather, he sent them

to her on purpose.

99. On July 24, 2020, TOMA told VALENTE “Check your email I’m

sending you a personal personal [sic] financial statement I need to fill out and

send it back to me immediately please takes one second of your time[.]”

VALENTE responded “This document cannot be done while I am at Crw too

Many eyes[.]”

100. On July 28, 2020, TOMA told VALENTE “I need you to fill that form

2
Your affiant, based on experience and review of other evidence, knows “P and L” to be a reference to profit and
loss statements.

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Case 2:26-mj-30001-DUTY ECF No. 1, PageID.80 Filed 01/05/26 Page 33 of 35

out that I sent you last week within the next hour and a half I need it signed and

sent to me either you take it to the bathroom whatever you Gotta do I need it

please[.]” VALENTE responded “Who is application for[?]”. TOMA responded

“SBA” and “Call me[.]”

101. This confirms that VALENTE and TOMA collaborated on her SBA

applications—which runs both the EIDL and PPP programs—rather than

VALENTE finding out after the fact.

102. Later the same day, TOMA asks VALENTE “did you sent me that

paper for the sba [?]”. TOMA then states “I shouldn’t have to ask you for

something for one week you’re the one who needs it right.” VALENTE says “no

we will discuss this evening including IRS stunt.”

103. On July 29, 2020, VALENTE texted TOMA “you already have my

tax returns which is all you need to do what paperwork you have to file[.]”

104. On August 3, 2020, VALENTE asked TOMA “What is happening

with the ppp loans[?]”. TOMA responds “working on it[.]” VALENTE asks

“And what’s the status[?]” TOMA responds “When I know you will know[.]”

VALENTE responds “We are running out of time[.]”

105. This, again, belies VALENTE’s claims that he did not know about the

PPP applications until after the fact. Rather, he knew, collaborated, and wanted
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his wife to apply. Recall also that VALENTE personally told investigators that

TOMA’s companies existed only on paper.

106. That same day, August 3, 2020, TOMA applied for two PPP loans

through Cache Valley Bank. On behalf of Detroits Red Light District 2 LLC,

TOMA claimed average monthly payroll of $168,412.00, and 24 employees. On

behalf of DF Worldwide, TOMA claimed average monthly payroll of

$106,669.00, and 15 employees.

107. On August 14, TOMA applied for another PPP loan through Newtek

AB for Building Detroit Group LLC, stating the average payroll as $246,733.00

and claiming 37 employees.

108. On August 13, 2020, TOMA texted VALENTE an SBA approval pdf

and said “Call me. Should have money for this one in account by Monday.”

109. On August 15, 2020, VALENTE texted TOMA: Well Done[.]”

110. Over the next year, VALENTE and TOMA texted frequently about

use of the PPP funds.

111. On March 5, 2021, VALENTE texted TOMA “"Need to get our Cash

flow in order. The ppp money will not last long.” This is a full year before 2022,

when VALENTE claims that he discovered the PPP funds.

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CONCLUSION

112. Based on the forgoing, there is probable cause to believe that PETER

VALENTE and ANGELA TOMA have conspired to commit wire fraud (18 U.S.C.

§ 1343), in violation of 18 U.S.C. § 1349, through their scheme to obtain PPP and

EIDL benefits by means of false and fraudulent pretenses and representations. In

addition, there is probable cause to believe that PETER VALENTE obstructed

justice, in violation of 18 U.S.C. § 1503.

Respectfully submitted,

Victor VanMeerbeeck
Special Agent, HSI

Sworn to before me and signed in my
presence and/or by reliable electronic means.

_________________________________________
HON. Kimberly G. Altman
United States Magistrate Judge

January 5, 2026

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