Indictment — United States v. Timmy G. Robinson Jr., Eastern District of Kentucky (Doc. 1)

Summary

An indictment in United States v. Timmy G. Robinson, Jr., No. 0:26-cr-00033, in the U.S. District Court for the Eastern District of Kentucky, Northern Division at Ashland, filed June 4, 2026 as Document 1. The grand jury charges one count of wire fraud under 18 U.S.C. § 1343 and two counts of money laundering under 18 U.S.C. § 1957. It states that Robinson owned Addiction Recovery Care, LLC (ARC), which sought Employee Retention Credits of $3,319,220 and $3,589,252 for the first and second quarters of 2021. The indictment charges that Robinson sold both credits to Buyer 1, then sold them again to Buyer 2, which wired $4,739,843.18, while concealing the earlier sale. It includes a forfeiture allegation and a penalties page listing not more than 20 years imprisonment for Count 1.

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Case: 0:26-cr-00033-DLB-EBA Doc#:1_ Filed: 06/04/26 Page: 1 of 8 - Page ID#:

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Eastern District of Kentucky
UNITED STATES DISTRICT COURT FILED
EASTERN DISTRICT OF KENTUCKY JUN 94 2006
NORTHERN DIVISION
ASHLAND ay CexiyeroN

OLERK U.S. DISTRICT COURT

UNITED STATES OF AMERICA

v. INDICTMENT NO. 20-33 DUB-E RA

TIMMY G. ROBINSON, JR.

THE GRAND JURY CHARGES:

BACKGROUND

At all relevant times:

l. TIMMY G. ROBINSON, JR. was a resident of Louisa, Kentucky and was a
licensed attorney in the Commonwealth of Kentucky.

2. ROBINSON owned Addiction Recovery Care, LLC (ARC), and functioned as
its Chief Executive Officer.

3. ARC was a behavioral health and substance abuse treatment provider with
residential facilities and outpatient facilities in the Eastern District of Kentucky.

4. The Internal Revenue Service (IRS) offered a refundable tax credit called an
Employee Retention Credit (ERC) to certain eligible businesses who paid qualified wages to
some or all of its employees between March 12, 2020 and January 1, 2022, and who were

impacted in specified ways by the COVID-19 pandemic. Eligible employers could claim the
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ERC on an adjusted employment tax return for one or more calendar year quarters within

those dates.

18 U.S.C. § 1343

5. The allegations set forth in paragraphs 1-4 of this Indictment are realleged and
incorporated by reference as if fully set forth herein.

6. Between on or about October 1, 2025, through on or about January 12, 2026, in
Lawrence County, in the Eastern District of Kentucky, and elsewhere,

TIMMY G. ROBINSON, JR.
knowingly, and with intent to defraud, devised and intended to devise a scheme to defraud
and obtain money by means of materially false and fraudulent pretenses, representations,
and promises, and concealment of material facts.
MANNER AND MEANS

7. In or around August 2023, ARC sought an ERC from the IRS in the amount of
$3,319,220, based on qualified employee wages it paid in the first quarter of 2021 (the “Q1
ERC”).

8. In or around April 2025, ARC sought an ERC from the IRS in the amount of
$3,589,252, based on qualified employee wages it paid in the second quarter of 2021 (the “Q2
ERC”).

9. On or about July 18, 2025, ROBINSON caused ARC to sell all of its rights,
title, and interest in the Ql ERC to Buyer 1. Under the terms of the sale agreement, Buyer 1

would pay ARC $2,721,761, and in exchange, ARC would cause the $3,319,220 Q1 ERC to
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be transferred to Buyer 1 after it was issued by the IRS. ROBINSON signed the sale

agreement on behalf of ARC.

10... Onor about July 22, 2025, Buyer 1 wired $2,721,761 to an ARC bank account.

11. The sale agreement with Buyer 1 required ARC to effectuate the release of a
third-party lien on the QI ERC within sixty days of July 22, 2025. If ARC failed to do so,
Buyer 1 could force ARC to repay the purchase price of the Ql ERC.

12. On or about September 24, 2025, ROBINSON executed an amendment to the
sale agreement on behalf of ARC, pursuant to which ARC transferred all of its rights, title,
and interest in the Q2 ERC to Buyer 1, in exchange for a thirty-day extension of the lien
release deadline described above in paragraph 12.

13. Thereafter, in order to unlawfully enrich himself and ARC, ROBINSON
devised a scheme to sell the Q1 ERC and Q2 ERC to a second buyer.

14. On or about October 27, 2025, ROBINSON falsely represented to Broker 1
that the Q1 ERC and Q2 ERC were available to purchase from ARC. ROBINSON concealed
the prior transactions of the same ERCs with Buyer I.

15. Throughout a due diligence process conducted by Broker 1 between October
27, 2025 and November 12, 2025, ROBINSON continued to falsely represent that the Q1
ERC and Q2 ERC were available for purchase from ARC, and continued to conceal that ARC
had already sold the same assets to Buyer 1.

16. On or about November 12, 2025, ROBINSON executed a sale agreement with
Buyer 2, pursuant to which Buyer 2 agreed to pay ARC $2,987,298, in exchange for ARC

remitting the Ql] ERC to Buyer 2 upon receipt from the IRS. In the sale agreement,
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ROBINSON falsely represented that no portion of the Ql ERC had been previously sold,

transferred, or subject to any lien or encumbrance. On or about November 12, 2025,
ROBINSON electronically signed the sale agreement and caused it to be transmitted via
interstate wire communication to Broker 1.

17. Onor about November 12, 2025, ROBINSON executed a sale agreement with
Buyer 2, pursuant to which Buyer 2 agreed to pay ARC $3,230,326, in exchange for ARC
remitting the Q2 ERC to Buyer 2 upon receipt from the IRS. In the sale agreement,
ROBINSON falsely represented that no portion of the Q2 ERC had been previously sold,
transferred, or subject to any lien or encumbrance. On or about November 12, 2025,
ROBINSON electronically signed the sale agreement and caused it to be transmitted via
interstate wire communication to Broker 1.

18. Onor about November 12, 2025, Buyer 2 wired an initial purchase payment of
$4,739,843.18 for the Ql ERC and Q2 ERC to an ARC bank account at Community Trust
Bank ending in *7593.

19. On December 2, 2025, ARC received the Ql ERC and Q2 ERC from the IRS.
ROBINSON directed ARC not to convey these funds to either Buyer 1 or Buyer 2. At
ROBINSON’S direction, ARC spent the ERC funds on other operational costs and debt
obligations.

EXECUTION OF THE SCHEME

20. On or about the date listed below, in Lawrence County, in the Eastern District

of Kentucky, and elsewhere,
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TIMMY G. ROBINSON, JR.,
for the purpose of executing the scheme described above, knowingly caused to be
transmitted, by means of wire communication in interstate commerce, the following

writings and signals:

Count | Date Wire Transmission

1 11/12/2025 | Signed sale agreements with Buyer 2 falsely representing that
the Q1 ERC and Q2 ERC had not been sold previously.

In violation of 18 U.S.C. § 1343.

COUNTS 2-3
18 U.S.C. § 1957

21. The allegations set forth in paragraphs 1-20 of this Indictment are realleged and
incorporated by reference as if fully set forth herein.

22. Onor about the dates listed below, in Lawrence County, in the Eastern District
of Kentucky, and elsewhere,

TIMMY G. ROBINSON, JR.

knowingly engaged, and attempted to engage, in a monetary transaction in criminally
derived property of a value greater than $10,000 and that was derived from specified
unlawful activity, that is, wire fraud in violation of 18 U.S.C. § 1343, by authorizing the

following:

Count | Date Amount Description

2 11/17/2025 | $325,000 Wire payment to ARC Account x0157 at Truist Bank
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3 11/22/2025 | $997,500 Wire payment to Neubert, Pepe & Monteith, P.C.

Each in violation of 18 U.S.C. § 1957.

FORFEITURE ALLEGATION
18 U.S.C. § 981(a)(1)(C)
18 U.S.C. § 982(a)(1)
28 U.S.C. § 2461

l. By virtue of the commission of the offense alleged in Count 1 of the Indictment,
TIMMY G. ROBINSON, JR. shall forfeit to the United States any and all property, real or
personal, which constitutes or is derived from proceeds traceable to the violation of 18 U.S.C.
§ 1343. Any and all interest that TIMMY G. ROBINSON, JR. has in this property is vested
in and forfeited to the United States pursuant to 18 U.S.C. § 981(a)(1)(C) and 28 U.S.C.
§ 2461.

2. By virtue of the commission of the offenses alleged in Counts 2 and 3 of the
Indictment, TIMMY G. ROBINSON, JR. shall forfeit to the United States any and all
property, real or personal, involved in the violations of 18 U.S.C. § 1957 and any property
traceable to such property. Any and all interest that TIMMY G. ROBINSON, JR. has in this
property is vested in and forfeited to the United States pursuant to 18 U.S.C. § 982(a)(1).

3. The property to be forfeited includes, but is not limited to, the following:

MONEY JUDGMENT:

A forfeiture money judgment in the amount of proceeds obtained by the Defendant as

a result of the fraud offense and/or in the amount involved in the money-laundering
offenses.

4. If any of the property listed 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
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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 shall be entitled to

forfeit substitute property pursuant to 21 U.S.C. § 853(p).

A TRUE BILL

JASON D. PARMAN
FIRST ASSISTANT UNITED STATES ATTORNEY
Case: 0:26-cr-00033-DLB-EBA Doc#:1_ Filed: 06/04/26 Page: 8 of 8 - Page ID#:

COUNT 1:

COUNTS 2-3:

PLUS:

PLUS:

PLUS:

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PENALTIES

Not more than 20 years imprisonment, a fine of $250,000 or
twice the gross gain or loss, whichever is greater, and 3 years
supervised release.

Not more than 10 years imprisonment, a fine of $250,000, and 3
years supervised release.
Mandatory special assessment of $100 per count.

Forfeiture, as alleged.

Restitution, if applicable.


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