Indictment — No. 1:21-cr-00013 (Dkt. 1, N.D. Fla.)

Summary

An indictment, Dkt. 1, in United States v. Jeremie Saintvil, also known as "Jeremie Stvil", "Jeremie Saint Vil" and "Jeremi Stvil", No. 1:21-cr-00013, in the U.S. District Court for the Northern District of Florida, Gainesville Division. Count One begins with an introduction describing the Small Business Administration, the Paycheck Protection Program under the CARES Act, Economic Injury Disaster Loans, and the credit unions and banks that offered PPP loans. The indictment alleges that business entities including HEJ Holding, Inc., Root Capital, Inc., Verb World, Inc., Kramer Corp and Martin Consulting, Inc. were not registered to do business in Florida and did not have the employees or payroll stated on their applications. It ends with a forfeiture section listing electronic devices and bank accounts.

Summary drafted by a model from the document's text below and checked by script against that text before publication. It is a navigation aid, not a reading of what the document proves. Where AI is used

Full text

Text recognized from a scanned document; may contain errors.

IN THE UNITED STATES DISTRICT COURT
FOR THE NORTHERN DISTRICT OF FLORIDA —
GAINESVILLE DIVISION

UNITED STATES OF AMERICA
v. INDICTMENT
JEREMIE SAINTVIL ‘DICK Aug
a/k/a “JEREMIE STVIL”
a/k/a “JEREMIE SAINT VIL”
a/k/a “JEREMI STVIL”

THE GRAND JURY CHARGES:

COUNT ONE
A. INTRODUCTION

At all times material to this Indictment:

1, The United States Small Business Administration (“SBA”) was an
executive-branch agency of the United States government that provides 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.

2. As part of this effort, the SBA enabled and provided for loans through

banks, credit unions, and other lenders. These loans had government-backed : Ae

guarantees.
The Paycheck Protection Program

3. The Coronavirus Aid, Relief, and Economic Security ("CARES") Act
was a federal law enacted in or around March 2020, and was designed to provide
emergency financial assistance to the millions of Americans who are suffering the
economic effects caused by the COVID-19 pandemic. One source of relief
provided by the CARES Act was the authorization of up to $349 billion in
forgivable loans to small businesses for job retention and certain other expenses,
through a program referred to as the SBA Paycheck Protection Program ("PPP").
In or around April 2020, Congress authorized over $300 billion in additional PPP
funding.

4, In order to obtain a PPP loan, a qualifying business was required to
submit a PPP loan application, called an SBA Form 2483. 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) was required to certify, 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 were required to provide documentation showing their payroll
2
expenses and that they were in business as of February 15, 2020. Further,
businesses applying for a PPP loan were required to make good faith
certifications, including that economic uncertainties had necessitated their loan
requests for continued business operations, and that they intended to use loan
proceeds only for the authorized, and not any duplicative, purposes.

5. PPP loan applications were required to be signed by an authorized
representative of the business. By signing PPP loan applications, applicants
attested that the information provided in the application and in all supporting
documents and forms was true and accurate, and that the applicant understood that
knowingly making a false statement to obtain a PPP loan was a crime.

6. PPP loan proceeds must have been used by the business on certain
permissible expenses- payroll costs, interest on mortgages, rent, and utilities. The
SBA 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 (usually eight weeks of receiving the proceeds) and used at least
75% of the PPP loan proceeds on payroll expenses.

7. A PPP loan application was required to be processed by a
participating financial institution (“the lender”). Ifa PPP loan application was
approved, the lender funded the PPP loan using its own monies, which were 100%

guaranteed by the SBA. Data from the loan application, including information
3
about the borrower, the total amount of the loan, and the listed number of
employees, was electronically transmitted by the lender to the SBA in the course
of processing the loan.

Economic Injury Disaster Loans

8. Another related response to the COVID-19 outbreak was an
expansion of an existing disaster-related program — the Economic Injury Disaster
Loan (“EIDL”) — to provide for loan assistance (including $10,000 advances) for
small businesses and other eligible entities for loans up to $2 million. The EIDL
proceeds could have been used to pay fixed debts, payroll, accounts payable, and
other bills that could have been paid had the disaster not occurred; however, such
loan proceeds were not intended to replace lost sales or profits, or for the
expansion of a business.

9. Unlike certain other types of SBA-guaranteed loans, EIDL funds were
issued directly from the United States Treasury, and applicants applied for EIDL
funds directly through the SBA via an online portal and application. The EIDL
application process, which also used certain outside contractors for system support,
collected information concerning the business and the business owner, including:
information about the gross revenues for the business prior to January 31, 2020;
and the cost of goods sold. Applicants electronically certified that the information

provided was true and accurate and were warned that any false statement or
4
misrepresentation to the SBA, or any misapplication of loan proceeds may result in
sanctions, including criminal penalties.

Financial Institutions

10. Florida Credit Union (“FCU”), Navy Federal Credit Union (“NFCU”),
and Guardians Credit Union (“GCU”) were financial institutions, the deposits of
which were federally insured by the National Credit Union Share Insurance Fund.
FCU, NFCU, and GCU offered PPP loans to its customers.

11. Celtic Bank (“Celtic”), Wells Fargo Bank, N.A. (“Wells Fargo”), TD
Bank, N.A. (“TD Bank”), Bank of America, N.A. (“BOA”), U.S. Century Bank.
(“USCB”), and Bank OZK (“BOZK”) were financial institutions, the deposits of
which were federally insured by the Federal Deposit Insurance Corporation.
Celtic, Wells Fargo, TD Bank, BOA, USCB, and BOZK offered PPP loans to its
customers.

12.. BOA, Capital One Bank, N.A. (“Capital One”), J.P. Morgan Chase |
Bank (“Chase”), American Express (“AMEX”), and Discover Card (“Discover”)
were financial institutions, the deposits of which were federally insured by the
Federal Deposit Insurance Corporation. BOA, Capital One, Chase, AMEX, and

Discover offered debit cards and credit cards to its customers.
Business Entity Applicants

HEJ Holding, Inc.

13. HEJ Holding, Inc., a purported corporation with a Tax Identification
Number (“TIN”) ending in 6480 and a business address in Florida, was not a
business entity that was registered to do business in Florida. HEJ Holding, Inc. did
not have 17 employees, nor did it pay an average of approximately $64,000 in
monthly payroll expenses.

14. R.J.H., born in 1926, was a resident of a senior living facility that
offered assisted living, memory, and respite care services. R.J.H. was not the
Chief Executive Officer (“CEO”) of any businesses, especially any in Florida,
including HEJ Holding, Inc.

Root Capital, Inc.

15. Root Capital, Inc., a purported corporation with a TIN ending in 4330
and a business address in Florida, was not a business entity that was registered to
do business in Florida. Root Capital, Inc. did not have 17 employees, nor did it
pay an average of approximately $80,000 in monthly payroll expenses.

16. R.H.R., born in 1938, was a resident of a senior living facility located
in Florida. R.H.R. was not the CEO of any businesses, especially in Florida,

including Root Capital, Inc.
Verb World, Inc.

17. Verb World, Inc., a purported corporation with a TIN ending in 4787
and a business address in Florida, was not a business entity that was registered to
do business in Florida. Verb World, Inc. did not have seven employees, nor did it
pay an average of approximately $41,000 in monthly payroll expenses.

Kramer Corp

18. Kramer Corp, a purported corporation with a TIN ending in 7622 and
a business address in Florida, was not a business entity that was registered to do
business in Florida. Kramer Corp did not have 17 employees, nor did it pay an
average of approximately $76,000 in monthly payroll expenses.

19. B.LK., born in 1931, was a resident of a senior living facility located
in Florida. B.L.K. was not the CEO of any businesses, especially in Florida,
including Kramer Corp.

Martin Consulting, Inc.

20. Martin Consulting, Inc., a purported corporation with a TIN ending in
4398 and a business address in Florida, was not a business entity that was
registered to do business in Florida. Martin Consulting, Inc. did not have 17
employees, nor did it pay an average of approximately $63,000 in monthly payroll

expenses.
21. M.J.J., born in 1920, was a resident of a senior living facility located
in Florida. M.J.J. was not the CEO of any businesses, especially in Florida,
including Martin Consulting, Inc.

Doherty and Associate, Inc.

22. Doherty and Associate, Inc., a purported corporation with a TIN
ending in 0492 and a business address in Florida, was not a business entity that
was registered to do business in Florida. Doherty and Associate, Inc. did not have
17 employees, nor did it pay an average of approximately $63,000 in monthly
payroll expenses.

23. R.R.D., born in 1929, was a resident of a senior living facility located
in Florida. R.R.D. was not the CEO of any businesses, especially in Florida,
including Doherty and Associate, Inc.

McCartney and Associates, Inc.

24. McCartney and Associates, Inc., a purported corporation with a ‘TIN
ending in 2888 and a business address in Florida, was not a business entity that
was registered to do business in Florida. McCartney and Associates, Inc. did not
have 17 employees, nor did it pay an average of approximately $42,000 in monthly

payroll expenses.
25. T.L.M., born in 1938, was a resident of a senior living facility located
in Florida. T.L.M. was not the CEO of any businesses, especially in Florida,
including McCartney and Associates, Inc.

RMC Acceptance, Inc.

26. RMC Acceptance, Inc., a purported corporation with a TIN ending in
0319 and a business address in Florida, was not a business entity that was
registered to do business in Florida. RMC Acceptance, Inc. did not have 17
employees, nor did it pay an average of approximately $84,000 in monthly payroll
expenses.

27. R.M.C., born in 1940, was a resident of a senior living facility located
in Florida. R.M.C. was not the CEO of any businesses, especially in Florida,
including RMC Acceptance, Inc.

Recovery and Empowerment for Family and Youth Services Center, Inc. |

28. Recovery and Empowerment for Family and Youth Services Center,
Inc., a corporation with a TIN ending in 3284 and a business address in Florida,
was a business entity that was registered to do business in Florida. Recovery and
Empowerment for Family and Youth Services Center, Inc. had not filed any
federal income tax returns since 2016 and did not use any third-party payroll

services.
29. E.S., born in 1942, was a relative of the defendant, JEREMIE
SAINTVIL (a/k/a JEREMIE STVIL, JEREMIE SAINT VIL, JEREMI
STVIL). E.S. was an owner and director of Recovery and Empowerment for
Family and Youth Services Center, Inc.

B. THE CHARGE

Between on or about February 1, 2018, and on or about June 30, 2020, in the

Northern District of Florida and elsewhere, the defendant,
JEREMIE SAINTVIL,
a/k/a “JEREMIE STVIL,”
a/k/a “JEREMIE SAINT VIL,”
a/k/a “JEREMI STVIL,”

did knowingly and willfully execute and attempt to execute a scheme and artifice
to defraud a federally insured financial institution, that is, FCU, NFCU, GCU,
Celtic, Wells Fargo, TD Bank, BOA, USCB, BOZK, Capital One, Chase, AMEX,
and Discover, and to obtain moneys owned by and under the custody and control
of FCU, NFCU, GCU, Celtic, Wells Fargo, TD Bank, BOA, USCB, BOZK,

Capital One, Chase, AMEX, and Discover by means of materially false and

fraudulent pretenses, representations, and promises.

10
C. THE FRAUDULENT SCHEME

It was part of the scheme that the defendant, JEREMIE SAINTVIL, a/k/a
“JEREMIE STVIL,” a/k/a “JEREMIE SAINT VIL,” a/k/a “JEREMI
STVIL,”:

1. Fraudulently obtained and possessed the means of identification and
the identification documents of elderly individuals, including that of E.L.H.,
R.JLH., R-ALR., B.LK., M.J.J., R-R.D., T.L.M., R.M.C., and E.S.

2. Fraudulently applied for and opened accounts and lines of credit at
financial institutions and credit card companies in the names of — and using the
means of identification and the identification documents that belonged to — elderly
individuals, including M.B., C.L.F., E.L.H., R.J.H., R-ALR., B.ILK., M.J.J., R.R.D.,
T.L.M., and R.M.C.

3. Fraudulently obtained and possessed physical checks, debit cards, and
credit cards in the names of elderly individuals, including R.J.H., R.H.R., B.LK.,
M.J.J., and R.R.D.

4. Fraudulently obtained and possessed debit card numbers and credit
card numbers linked to bank accounts and lines of credit that were fraudulently
opened in the names of — and using the means of identification and the
identification documents that belonged to — elderly individuals, including C.L.F.,

E.L.H., R-H.R., M.J.J., and R.R.D.
11
5, Used the services of an electronic payments processor to transfer
funds from the fraudulently obtained lines of credit — including those in the names
of R.H.R., C.L-F., M.J.J., and R.R.D. — into bank accounts at Wells Fargo which
were fraudulently opened using the PII of elderly individuals, including M.B.,
C.L.F., and R.HLR.

6. | Made and caused to be made false and fraudulent representations in
SBA PPP loan applications and in supporting loan documents submitted to FCU,
NFCU, GCU, Celtic, Wells Fargo, TD Bank, BOA, USCB, and BOZK in the name
of inactive and fictitious businesses, namely, HEJ Holding, Inc., Root Capital, Inc.,
Martin Consulting, Inc., Doherty and Associate, Inc., Kramer Corp, RMC
Acceptance, Inc., McCartney and Associates, Inc., Recovery and Empowerment,
Inc., and Verb World, Inc., using the means of identification and the identification
documents of himself and of elderly individuals, including R.J.H., R.ALR., B.LK.,
M.J.J., R.R.D., T.L.M., R.M.C., and E.S., in order to falsely qualify for SBA PPP
loans.

7. Specifically attempted to cause FCU to issue an SBA PPP loan and
disburse SBA PPP loan proceeds to him based upon a loan application, loan
documents, and emails that falsely represented that: (a) he was a nonagenarian
named R.J.H., the CEO of HEJ Holding, Inc., and (b) that HEJ Holding, Inc. had

17 employees and had an average monthly payroll of approximately $63,000.
12
8. Electronically mailed and submitted false and fraudulent

documentation to FCU, NFCU, GCU, Celtic, Wells Fargo, TD Bank, BOA, USCB,

and BOZK for the SBA PPP loan applications.

9, Specifically mailed and submitted, by electronic means,

documentation to FCU for the SBA PPP loan application, including:

a. a Florida Identification Card in the name of R.J.H.,

b. a false 2019 U.S. Corporation Income Tax Return (Form 1120)
for HEJ Holding, Inc.,

C, a false 2019 Employer’s Annual Federal Unemployment
(FUTA) Tax Return (Form 940) for HEJ Holding, Inc.,

d. a false 2020 Quarter 1 Employer’s Quarterly Federal Tax
Return (Form 941),

e. a false Internal Revenue Service Form SS-4 regarding HEJ
Holding, Inc, and

f. a false Paychex document labeled “Paycheck Protection
Program Data”

10. Communicated, via email and telephone, with the financial

institutions at which he applied for SBA PPP loans about the status of his loan

applications and the funding of such loans.

13
11. Fraudulently obtained and attempted to obtain more than $1,500,00 in
monies, funds, and credits owned by and under the custody and control of FCU,
NEFCU, GCU, Celtic, Wells Fargo, TD Bank, BOA, USCB, BOZK, Capital One,
Chase, AMEX, and Discover by this conduct.

D. EXECUTION OF THE SCHEME

Between on or about May 4, 2020, and on or about May 21, 2020, for the
purpose of executing and attempting to execute this fraudulent scheme, the
defendant, JEREMIE SAINTVIL, a/k/a “JEREMIE STVIL,” a/k/a
“JEREMIE SAINT VIL,” a/k/a “JEREMI STVIL,” did knowingly and
willfully submit false and fraudulent representations to FCU in an SBA PPP loan
application, and in supporting loan documents and emails.

In violation of Title 18, United States Code, Sections 1344 and 2.

COUNT TWO
A. INTRODUCTION

The allegations of Section A of Count One are hereby realleged and

incorporated by reference as if fully set forth herein.
B. THE CHARGE
Between on or about May 4, 2020, and on or about May 21, 2020, in the

Northern District of Florida, the defendant,

14
JEREMIE SAINTVIL,
a/k/a “JEREMIE STVIL,”
a/k/a “JEREMIE SAINT VIL,”
a/k/a “JEREMI STVIL,”
knowingly made a false statement to FCU, a federally insured financial institution,
for the purpose of influencing the action of FCU in connection with a loan, that is,
the defendant submitted an application for an SBA PPP loan that contained a false
business legal name, false business address, false business TIN, false average
monthly payroll cost, false number of employees, and false owner name, and false
supporting documentation, namely:
a. a false 2019 U.S. Corporation Income Tax Return (Form 1120)
for HEJ Holding, Inc.,
b, a false 2019 Employer’s Annual Federal Unemployment
(FUTA) Tax Return (Form 940) for HEJ Holding, Inc.,
C. a false 2020 Quarter 1 Employer’s Quarterly Federal Tax
Return (Form 941),
d. a false Internal Revenue Service Form SS-4 regarding HEJ
Holding, Inc, and
e. a false Paychex document labeled “Paycheck Protection

Program Data.”

In violation of Title 18, United States Code, Section 1014.

15
COUNT THREE
A. INTRODUCTION
The allegations of Section A of Count One are hereby realleged and
incorporated by reference as if fully set forth herein.
B. THE CHARGE
Between on or about May 4, 2020, and on or about May 21, 2020, in the
Northern District of Florida, the defendant,
JEREMIE SAINTVIL,
a/k/a “SEREMIE STVIL,”
a/k/a “JEREMIE SAINT VIL,”
a/k/a “JEREMI STVIL,”
did knowingly possess and use, without lawful authority, a means of identification
of another person, to wit: the name, social security number, date of birth, and
Florida Identification Card number of R.J.H., during and in relation to a felony
violation enumerated in Title 18, United States Code, Section 1028A(c), to wit:
bank fraud as charged in Count One of this Indictment, and making fraudulent
statements to a federally insured institution as charged in Count Two of this

Indictment.

In violation of Title 18, United States Code, Section 1028A(a)(1).

16
COUNT FOUR
A. INTRODUCTION
The allegations of Section A of Count One are hereby realleged and
incorporated by reference as if fully set forth herein.
B. THE CHARGE
Between on or about May 4, 2020, and on or about May 21, 2020, in the
Northern District of Florida, in a matter within the jurisdiction of the executive
branch of the Government of the United States, that is, the SBA’s administration of
its PPP and EIDL program, the defendant,
JEREMIE SAINTVIL,
a/k/a “JEREMIE STVIL,”
a/k/a “JEREMIE SAINT VIL,”
a/k/a “JEREMI STVIL,”
did knowingly and willfully falsify a material fact; make materially false, fictitious,
and fraudulent statements and representations; and make and use a false document
knowing the same to contain any materially false, fictitious, or fraudulent
statement or entry, to wit, the defendant falsely stated in an SBA PPP loan
application (SBA Form 2483) that he submitted to FCU to obtain an SBA PPP loan
that:

a. he was a nonagenarian named R.J.H., the CEO of HEJ Holding,

Inc.,

17
b. HES Holding, Inc. had 17 employees,

C. HEJ Holding, Inc. had an average monthly payroll of
approximately $63,000,

d. 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,

e, HEJ Holding, Inc. 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,

f. Current economic uncertainty made the SBA PPP loan
necessary to support ongoing operations of HEJ Holding, Inc.,

g. the SBA PPP loan funds will be used to retain works and
maintain payroll or make mortgage interest payments, lease payments, and
utility payments, as specified under the PPP Rule, and

h. the information provided in the SBA PPP loan application and
the information provided in all supporting documents and forms was true
and accurate in all material respects,

whereas, in truth and in fact, and as the defendant well knew, such representations
were contrary to the information described in Paragraphs 13 and 14 of Section A of

Count One.
18
In violation of Title 18, United States Code, Section 1001(a).
CRIMINAL FORFEITURE

The allegations contained in Counts One through Three of this Indictment
are hereby realleged and incorporated by reference for the purpose of alleging
forfeiture. From his engagement in the violations alleged in Counts One through
Three of this Indictment, the defendant,

JEREMIE SAINTVIL,
a/k/a “JEREMIE STVIL,”
a/k/a “JEREMIE SAINT VIL,”
a/k/a “JEREMI STVIEL,”

shall forfeit to the United States, pursuant to Title 18, United States Code, Sections
982(a)(2) and (3), and Title 28, United States Code, Section 2461(c), any and all of
the defendants’ right, title, and interest in any property, real and personal,
constituting, and derived from, proceeds traceable to such offenses. The United
States will also seek a forfeiture money judgment for a sum of money equal to the
value of any property, real or personal, which constitutes or is derived from
proceeds traceable to these offenses. The property to be forfeited includes, but is
not limited to, the following:

1. Documents, identification documents, and electronics seized by the

United States Internal Revenue Service Criminal Investigation and the Federal

19
Bureau of Investigation, pursuant to a search and seizure warrant executed on or

about June 18, 2020, including, but not limited to, the following:

a.

b.

k.

MacBook Pro bearing serial number CO2CP7WQMDOT,
Apple iMac bearing serial number D25PXOHQFY 14,

Apple iPad A-2069 bearing serial number DMPCKO36NTI3,
Apple iPad A-1652 bearing serial number DLXR87LFGMW3,
Apple iPad A-1671 bearing serial number DLXV305CHP34,
Apple iPad A-2069 bearing serial number DMPCGIOHNTI2,
Apple iPhone A-1387,

Lacie External Hard Drive bearing serial number NL34M8SX,
Seagate External Hard Drive bearing serial number
NL383D0H,

Apple iPhone-A-1661,

Seagate External Hard Drive bearing serial number NL383CTP,
Apple iPad,

Apple Time Capsule A1409 bearing serial number
C86JNSOUDM73,

SanDisk USB Drive, and

AT&T U-Verse ARRIS Router bearing serial number

194146947635296,
20
2. The Wells Fargo account ending in 2467, held in the name of Root
Capital,
3, The Ally Bank accounts ending in 8432 and 8421, held in the name of
' 4. The Ally Bank accounts ending in 3650 and 8986, held in the name of
M.J.J.,
5. | The GCU account ending in 77-7, held in the name of Doherty and
Associates, Inc., and
6. The NFCU account ending in 3857, held in the name of Kramer Corp.
If any of the property described above as being subject to forfeiture, as a
result of acts or omissions of the defendant:
1. cannot be located upon the exercise of due diligence;
ii. has been transferred, sold to, or deposited with a third party;
iii. has been placed beyond the jurisdiction of this Court;
iv. has been substantially diminished in value; or
V. has been commingled with other property that cannot be
subdivided without difficulty,
it is the intent of the United States, pursuant to Title 21, United States Code,

Section 853(p), as incorporated by Title 28, United States Code, Section 2461(c),

21
to seek forfeiture of any other property of said defendant up to the value of the

forfeitable property.

Acting United State: Aomey

Assistant United States Attorney

é

22


File and source

File

1.pdf

Size

544,155 bytes

SHA-256

36ad5351c0147093623940a489e06d6b5f0579051330fd50a8cdf0a647546393

Our copy

1.pdf

Original

No public link identified.