Criminal Information — United States v. Hunter Vanpelt a/k/a Hunter Lauren Vanpelt, No. 1:21-CR-00006 (Dkt. 1, N.D. Ga.)

Summary

This criminal information, filed January 11, 2021 as Document 1 in United States v. Hunter Vanpelt, No. 1:21-CR-00006, in the Northern District of Georgia, charges Hunter Vanpelt, also known as Ellen Corkrum, with bank fraud under Title 18, United States Code, Section 1344. It alleges that from about April 27, 2020 to June 17, 2020 PPP loan applications were submitted for six entities associated with Vanpelt, seeking $7,943,591.50, of which $6,017,066.50 was disbursed. The six include Georgia Nephrology Physician Associated, United Healthcare Group & Co., Nephrology Network Group LLC and Kiwi International Inc., and the information says the applications carried false payroll and employee figures, IRS records and bank statements. The forfeiture allegation lists seized funds, including $1,666,755.44 from a JPMorgan Chase account in the name of First Corporate International, Inc.

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Case 1:21-cr-00006-MHC Document 1 Filed 01/11/21 Page 1 ofFllED IN OPEN COURT
U.S.D.C. - Atlanta

JAN 41 2021
JAMES N. HATTEN, Clerk
By:
Deputy Clerk

IN THE UNITED STATES DISTRICT COURT
FOR THE NORTHERN DISTRICT OF GEORGIA
ATLANTA DIVISION

UNITED STATES OF AMERICA

Vv. Criminal Information

HUNTER VANPELT A/K/A No. 1:21-CR-00006
HUNTER LAUREN VANPELT
A/K/A ELLEN CORKRUM A/K/A
ELLEN YABBA KWAME
CORKRUM

THE UNITED STATES ATTORNEY CHARGES THAT:

Count One
Bank Fraud

1. From on or about April 27, 2020 through on or about June 17, 2020,
in the Northern District of Georgia and elsewhere, the defendant, HUNTER
VANPELT a/k/a HUNTER LAUREN VANPELT a/k/a ELLEN CORKRUM
a/k/a ELLEN YABBA KWAME CORKRUM did knowingly execute and attempt
to execute a scheme and artifice to defraud financial institutions, the deposits of
which were then insured by the Federal Deposit Insurance Corporation (FDIC),
and to obtain, by means of materially false and fraudulent pretenses,
representations, and promises moneys, funds, credits, assets, securities, and
other property owned by and under the custody and control of those financial

institutions, in violation of Title 18, United States Code, Section 1344.
Case 1:21-cr-OO006-MHC Document1 Filed 01/11/21 Page 2 of 10

Background
At times relevant to this Information:

The Small Business Administration

2, The United States Small Business Administration (SBA) was an
executive branch agency of the United States government that provided support
to entrepreneurs and small businesses. The mission of the SBA was to maintain
and strengthen the nation’s economy by enabling the establishment and viability
of small businesses and by assisting in the economic recovery of communities
after disasters.

3. As part of this effort, the SBA enabled and provided for loans
through banks, credit unions, and other lenders. These loans had government-
backed guarantees.

The Paycheck Protection Program

4, The Coronavirus Aid, Relief, and Economic Security (CARES) Act
was a federal law enacted in or about March 2020 and was designed to provide
emergency financial assistance to the millions of Americans who were suffering
the economic effects caused by the COVID-19 pandemic.

5. One source of relief that the CARES Act provided was the
authorization of up to $349 billion in forgivable loans to small businesses for
payroll, mortgage interest, rent/lease, and utilities, through a program referred
to as the Paycheck Protection Program (PPP). In April 2020, Congress authorized
up to $310 billion in additional PPP funding.
Case 1:21-cr-OO006-MHC Document1 Filed 01/11/21 Page 3 of 10

6. The PPP allowed qualifying small businesses and other
organizations to receive PPP loans. Businesses must use PPP loan proceeds for
payroll costs, interest on mortgages, rent, and utilities. The PPP allowed the
interest and principal on the PPP loan to be entirely forgiven if the business spent
the loan proceeds on these expense items within a designated period of time and
used a certain percentage of the PPP loan proceeds for payroll expenses.

7. The amount of a PPP loan that a small business may have been
entitled to receive was determined by the number of employees employed by the
business and the business’s average monthly payroll costs.

8. In order to obtain a PPP loan, a qualifying business was required to
submit a PPP loan application, which was signed by an authorized
representative of the business. The PPP loan application required the business
(through its authorized representative) to acknowledge the program rules and
make certain affirmative certifications in order to be eligible to obtain the PPP
loan. In the PPP loan application, the small business (through its authorized
representative) had to state, among other things, its (a) average monthly payroll
expenses and (b) number of employees. These figures were used to calculate the
amount of money the small business was eligible to receive under the PPP. In
addition, businesses applying for a PPP loan had to provide documentation
showing their payroll expenses.

9. Specifically, the applicant had to certify the following:
Case 1:21-cr-OO006-MHC Document1 Filed 01/11/21 Page 4 of 10

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; I understand that if
the funds are knowingly used for unauthorized purposes, the federal
government may hold me legally liable, such as for charges of fraud.

10. The SBA oversaw the PPP. However, individual PPP loans were
issued by private, approved lenders who received and processed PPP
applications and supporting documentation directly or through third-party
processors, and then made loans using the lenders’ own funds, which were 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,
was transmitted by the lender to the SBA in the course of processing the loan.

The Defendant

11. ELLEN CORKRUM a/k/a ELLEN YABBA KWAME CORKRUM
changed her name to HUNTER LAUREN VANPELT a/k/a HUNTER
VANPELT in or about July 2016. VANPELT used both names, VANPELT and
CORKRUM, after changing her name to VANPELT, and submitted PPP loan
applications under both names. VANPELT was a resident of Roswell, Georgia.

Relevant Financial Institutions and Affiliates

12. Financial Institution 1 was an FDIC-insured financial institution
based in San Francisco, California. Financial Institution 1 was an SBA-approved
lender and participated as a PPP lender.

13. Financial Institution 2 was an FDIC-insured financial institution
based in Salt Lake City, Utah. Financial Institution 2 was an SBA-approved

lender and participated as a PPP lender.

4
Case 1:21-cr-O0006-MHC Document1 Filed 01/11/21 Page 5 of 10

14. ‘Financial Institution 3 was an FDIC-insured financial institution
based in Fort Lee, New Jersey. Financial Institution 3 was an SBA-approved
lender and participated as a PPP lender.

15. Financial Institution 4 was an FDIC-insured financial institution
based in Salt Lake City, Utah. Financial Institution 4 was an SBA-approved
lender and participated as a PPP lender.

16. Company 1 was a financial technology company based in Redwood
City, California. Company 1 participated in the PPP by, among other things,
acting as a service provider between small businesses and certain lenders,
including Financial Institution 2 and Financial Institution 3. Small businesses
seeking PPP loans could apply through Company 1 for PPP loans. Company 1
would review the PPP loan applications. If a PPP loan application received by
Company 1 was approved for funding, a partner lender, such as Financial
Institution 2 and Financial Institution 3, disbursed the PPP loan funds to the

applicant.
Manner and Means

17. From on or about April 27, 2020 to on or about June 17, 2020, false
and fraudulent PPP loan applications were submitted on behalf of six entities
associated with VANPELT. The amounts requested in the six PPP loans totaled
$7,943,591.50, of which $6,017,066.50 was disbursed as follows:

4/27/2020 | 12 $197,951 $494,877 $494,877

Georgia Nephrology Financial
Physician Associated Institution 1
United Healthcare Group Financial 4/30/2020 31 $230,849 $577,122 $577,122
& Co. Institution 2
Case 1:21-cr-OO006-MHC Document1 Filed 01/11/21 Page 6 of 10

“Nephrology Network | Financial | 5/13/2020 | +~« 86) ~~«*$659;,342'| ~~—~—«*$:1,648,355 $1,648,355
Group LLC Institution 2

First Corporate Financial 5/14/2020 86 $659,342 $1,648,355 $1,648,355
International Institution 3

Corkrum Consolidated Inc. | Financial 6/16/2020 91 $770,610 $1,926,525 $0
Institution 2

Kiwi International Inc. Financial 6/17/2020 86 $659,343 | $1,648,357.50 | $1,648,357.50
Institution 4

TOTALS: $7,943,591.50 | $6,017,066.50

Fraudulent PPP Loan Applications
18. . VANPELT owned or controlled the six entities that sought the PPP

loans described above: Georgia Nephrology Physician Associated, United

Healthcare Group & Co., Nephrology Network Group LLC, First Corporate

International, Corkrum Consolidated Inc., and Kiwi International Inc.

(collectively, the “VANPELT Entities”).
19. VANPELT submitted and caused to be submitted six false and
fraudulent PPP loan applications on behalf of the VANPELT Entities to Financial

Institution 1, Financial Institution 2, Financial Institution 3, Financial Institution
4, and Company 1. VANPELT signed two of these PPP loan applications using
the HUNTER VANPELT name, signed one of the PPP loan applications using the
HUNTER LAUREN VANPELT name, and signed three of the PPP loan
applications using the ELLEN CORKRUM name.

20. Ineach of the PPP loan applications for the VANPELT Entities,
VANPELT falsely certified that all information therein and in the supporting

documents was true and accurate.
Case 1:21-cr-OO006-MHC Document1 Filed 01/11/21 Page 7 of 10

21. Ineach of the PPP loan applications for the VANPELT Entities,
VANPELT falsely represented the average monthly payroll and the number of
employees working for the VANPELT Entities.

22. Insupport of each of the PPP loan applications for the VANPELT
Entities, VANPELT submitted false Internal Revenue Service (IRS) records.

23. Insupport of the PPP loan applications for United Healthcare Group
& Co., Nephrology Network Group LLC, First Corporate International, and
Corkrum Consolidated Inc., VANPELT submitted false bank statements that
purported to be from accounts associated with each of these entities.

24. Insupport of the PPP loan application for Kiwi International Inc.,
VANPELT submitted false payroll reports.

25. Based on the false and fraudulent PPP loan applications and
supporting documents submitted or caused to be submitted by VANPELT,
Financial Institution 1, Financial Institution 2, Financial Institution 3, Financial
Institution 4, and Company 1 approved five PPP loan applications and disbursed
$6,017,066.50 in PPP loan proceeds to accounts controlled by VANPELT.

26. The PPP loan proceeds were not used for payroll or for other
authorized PPP business expenses.

Execution of the Scheme to Defraud

27. Among other executions of the scheme, on or about April 30, 2020, in
the Northern District of Georgia and elsewhere, the defendant, HUNTER
VANPELT a/k/a HUNTER LAUREN VANPELT a/k/a ELLEN CORKRUM
a/k/a ELLEN YABBA KWAME CORKRUM, did knowingly execute and

7
Case 1:21-cr-OO006-MHC Document1 Filed 01/11/21 Page 8 of 10

attempt to execute the above-described scheme to defraud by submitting a false
and fraudulent PPP loan application to Financial Institution 2, through Company
1, on behalf of United Healthcare Group & Co., that included false
representations and certifications, false IRS records, and a false bank statement.
All in violation of Title 18, United States Code, Section 1344.
Forfeiture Allegation
28. Upon conviction of the offense alleged in Count One of this Criminal
Information, the defendant, HUNTER VANPELT a/k/a HUNTER LAUREN
VANPELT a/k/a ELLEN CORKRUM a/k/a ELLEN YABBA KWAME
CORKRUM, shall forfeit to the United States of America, pursuant to Title 18,
United States Code, Section 982(a)(2)(A), any property constituting, or derived
from, proceeds obtained directly or indirectly, as a result of such violation. The
property to be forfeited includes, but is not limited to, the following:
a) MONEY JUDGMENT: A sum of money in United States
currency, representing the amount of proceeds obtained as a
result of the offense for which the defendant is convicted.
b) FUNDS:
1) $8,401.00 in U.S. Currency seized from the defendant’s residence
on or about October 6, 2020;
2) $216,474.36 in funds seized from Navy Federal Credit Union
Account Number ending 8872 held in the name of Hunter Lauren

VanPelt;
Case 1:21-cr-OO006-MHC Document1 Filed 01/11/21 Page 9 of 10

3) $2,685.36 in funds seized from Minnco Credit Union Account
Number ending 6906 held in the name of Lucretia K. Turnquist;
4) $91,574.53 in funds seized from JPMorgan Chase Bank Account
Number ending 3083 held in the name Corkrum Consolidated
Inc.;
5) $69,636.43 in funds seized from JPMorgan Chase Bank Account
Number ending 3611 held in the name of Kiwi International Inc.;
6) $1,666,755.44 in funds seized from JPMorgan Chase Bank
Account Number ending 6303 held in the name of First
Corporate International, Inc.; and
7) $21,854.00 in funds seized from JPMorgan Chase Bank Account
Number ending 9031 held in the name of Nephrology Network
Group LLC.
29. If, any of the property described above, as a result of any act or
omission of the defendant:
(a) cannot be located upon the exercise of due diligence;
(b) has been transferred or sold to, or deposited with, a third party;
(c) has been placed beyond the jurisdiction of the Court;
(d) has been substantially diminished in value; or
(e) has been commingled with other property which cannot be divided
without difficulty;
the United States intends, pursuant to Title 21, United States Code, Section

853(p), as incorporated by Title 18, United States, Section 982(b)(1), to seek

9
Case 1:21-cr-OO006-MHC Document1 Filed 01/11/21 Page 10 of 10

forfeiture of any other property of said defendant up to the value of the above

forfeitable property.

BOBBY L. CHRISTINE
Acting United States Attorney

L247, HUBER

Assistant United States Attorney
Georgia Bar No. 545627

600 U.S. Courthouse

75 Ted Turner Drive SW
Atlanta, GA 30303
404-581-6000; Fax: 404-581-6181

DANIEL S. KAHN
Acting Chief, Fraud Section
United States Department of Justice

CHRIS A. WENGER
Trial Attorney
Criminal Division, Fraud Section

District of Columbia Bar No. 991048
1400 New York Avenue, NW

Bond Building - 4th Floor
Washington, DC 20005

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