Indictment — No. 1:20-cr-00454 (Dkt. 2, E.D.N.Y.)
Summary
An indictment in United States v. Jeremy Trapp, 1:20-cr-00454(AMD)(PK), Dkt. 2, in the U.S. District Court for the Eastern District of New York. Count One charges wire fraud in a scheme to defraud the Small Business Administration, citing an electronic transmission on or about June 18, 2020 of an Economic Injury Disaster Loan Program loan application. Count Two charges theft of government property in or about July 2020, with an aggregate value exceeding $1,000. Count Three charges a false statement to the SBA, alleging that he reported being the sole proprietor of a commercial car wash business with 10 employees and gross revenues of $150,000. It includes a criminal forfeiture allegation.
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“Indictment — No. 1:20-cr-00454 (Dkt. 2, E.D.N.Y.).”
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DMP:FJN/SKW
F. #2020R00621
UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF NEW YORK 1:20-cr-00454(AMD)(PK)
---------------------------X
UNITED STATES OF AMERICA INDICTMENT
- against- Cr. N o . - - - - - - - - - - -
(T. 18, U.S.C., §§ 641, 98l(a)(l)(C),
JEREMY TRAPP, 1014, 1343, 2 and 3551 et seq.; T. 21,
U.S.C., § 853(p); T. 28, U.S.C., §
Defendant. 2461(c))
--------------------------:-X
THE GRAND JURY CHARGES:
COUNT ONE
(Wire Fraud)
1. In or about and between June 2020 and July 2020, both dates being
approximate and inclusive, within the Eastern District ofNew York and elsewhere, the
defendant JEREMY TRAPP, together with others, did knowingly and intentionally devise a
scheme and artifice to defraud the Small Business Administration ("SBA"), and to obtain
money and property from the SBA by means of one or more materially false and fraudulent
pretenses, representations and promises, and for the purpose of executing such scheme and
artifice, did transmit and cause to be transmitted, by means of wire communications in
interstate commerce, writings, signs, signals, pictures and sounds, to wit: an electronic
transmission on or about June 18, 2020, of a :fraudulent Economic Injury Disaster Loan
Program loan application.
(Title 18, United States Code, Sections 1343, 2 and 3551 et seq.)
2
COUNT TWO
(Theft of Government Property)
2. In or about July 2020, within the Eastern District of New York and
elsewhere, the defendant JEREMY TRAPP, together with others, did knowingly and
willfully (i) steal, purloin and knowingly convert to his own use and the use of another,
money belonging to the United States and to a department and agency thereof, to wit:
Economic Injury Disaster Loan Program assistance provided by the SBA via the United
States Treasury, the aggregate value of which exceeded $1,000, and (ii) receive, conceal and
retain the same with intent to convert it to his own use and gain, knowing it to have been
stolen, purloined and converted.
(Title 18, United States Code, Sections 641, 2 and 3551 et seq.)
COUNT THREE
(False Statement to the Small Business Administration)
3. In or about and between June 2020 and July 2020, both dates being
approximate and inclusive, within the Eastern District of New York and elsewhere, the
defendant JEREMY TRAPP, together with others, did knowingly and intentionally make one
or more materially false statements and reports for the purpose of influencing the action of
the SBA, in connection with an application, advance, discount, purchase, purchase
agreement, repurchase agreement, commitment and loan, to wit: a fraudulent Economic
Injury Disaster Loan Program loan application, in that TRAPP falsely stated and reported
that he was the sole proprietor of a commercial car wash business, that the car wash business
was located at his residence, and that the car wash business had 10 employees and gross
revenues of $150,000 for the 12 months prior to the COVID 19 pandemic, when in fact as
3
TRAPP well knew and believed, TRAPP never operated a commercial car wash business, let
alone one that employed 10 persons and had $150,000 in gross revenue.
(Title 18, United States Code, Sections 1014, 2 and 3551. et seq.)
CRIMINAL FORFEITURE ALLEGATION
4. The United States hereby gives notice to the defendant that, upon his
conviction of any of the offenses charged herein, the government will seek forfeiture in
accordance with Title 18, United States Code, Section 981(a)(l)(C) and Title 28, United
States Code, Section 2461 (c), which require any person convicted of such offenses to forfeit
any property, real or personal, constituting, or derived from, proceeds obtained directly or
indirectly as a result of such offense.
5. If any of the above-described forfeitable property, 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;
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it is the intent of the United States, pursuant to Title 21, United States Code, Section 853(p),
to seek forfeiture of any other property of the defendant up to the value of the forfeitable .
property described in this forfeiture allegation.
(Title 18, United States Code, Section 98l(a)(l)(C); Title 21, United States
Code, Section 853(p); Title 28, United States Code, Section 2461 (c))
A TRUE BILL
~RS~
SETH D. DuCHARME
ACTING UNITED STATES ATTORNEY
EASTERN DISTRICT OF NEW YORK
F.#: 2020R00621
FORM DBD-34 No.
JUN. 85
UNITED STATES DISTRICT COURT
EASTERN District ofNEW YORK
CRIMINAL DIVISION
THE UNITED STATES OF AMERICA
vs.
JEREMY TRAPP,
Defendant.
INDICTMENT
(T. 18, U.S.C., §§ 641, 981(a)(l)(C), 1014, 1343, 2 and 3551 et~.; T.
21, U.S.C., § 853(p); T. 28, U.S.C., § 2461(c))
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A true I • a~----- Foree.erso
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Filed in open court this _________________ day,
of _ · ---------- A.D. 20 ____ _
Clerk
Ba~$ ___________________________________ _
Francisco!. Navarro and Sara K. Winik, Assistant United States Attorneys
(718) 254-7000
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