Indictment — United States v. Cameron Mills, Southern District of Georgia (Document 1)
Summary
An indictment filed May 10, 2022 as Document 1 in United States v. Cameron Mills, Case 1:22-cr-00042-JRH-BKE, in the U.S. District Court for the Southern District of Georgia, Augusta Division. The grand jury charges that on or about April 25, 2021 the defendant submitted a PPP loan application to Benworth Capital Partners, LLC seeking $20,833 and representing a sole proprietorship with $100,000 of gross income in 2019, which the indictment calls false. Count One charges bank fraud under 18 U.S.C. § 1344, Count Two charges a false statement on a loan application under 18 U.S.C. § 1014, and Count Three charges wire fraud under 18 U.S.C. § 1343. It states Benworth Capital approved the loan for $20,833 on April 28, 2021 and deposited $20,833.00 into the defendant's account at South State Bank.
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“Indictment — United States v. Cameron Mills, Southern District of Georgia (Document 1).”
Original at archive.org. Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/indictment-no-1-22-cr-00042-dkt-1-7d652fd8f7/
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Case 1:22-cr-00042-JRH-BKE Document 1 Filed 05/10/22 Page 1 of 7
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF GEORGIA
AUGUSTA DIVISION
Ct322-0G<
UNITED STATES OF AMERICA INDICTMENT NO.
V. 18U.S.C. § 1344
Bank Fraud
CAMERON MILLS
18 U.S.C. § 1014
False Statement on a Loan
Application
18 U.S.C. § 1343
Wire Fraud
THE GRAND JURY CHARGES THAT:
Introduction
UJ
1. The Coronavirus Aid, Relief, and Economic Security("CfARES^ Act^was
a federal law enacted in or about March 2020 designed to provide emergency financial
assistance to the millions who suffered economic effects caused by the COVID-19
pandemic.
2. Among other relief efforts, the United States sought to provide financial
support to eligible businesses that could be used to offset certain business expenses.
3. At all times material to this Indictment, the Small Business
Administration ("SBA") was an executive branch agency of the United States
government that provided support to entrepreneurs and small businesses. The SBA
was headquartered in Washington, DC and maintained its computer servers outside
of the State of Georgia. The SBA's mission was to maintain and strengthen the
nation's economy by enabling the establishment and viability of small businesses and
Case 1:22-cr-00042-JRH-BKE Document 1 Filed 05/10/22 Page 2 of 7
by assisting in the economic recovery of communities after disasters.
4. 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. In addition, the SBA provided loans that came directly from the U.S.
Government.
5. 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 Paycheck Protection
Program ("PPP"). In or around April 2020, Congress authorized over $300 bilhon in
additional PPP funding.
6. To obtain a PPP loan, a qualifying business had to submit a PPP loan
application 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 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
then used to calculate the amount of money the small business was ehgible to receive
under the PPP. In addition, a business applying for a PPP loan had to provide
documentation showing its payroll expenses.
7. A PPP loan application must be processed by a participating lender,
such as a financial institution. If a PPP loan is approved, the participating lender
Case 1:22-cr-00042-JRH-BKE Document 1 Filed 05/10/22 Page 3 of 7
funds the PPP loan using its own monies, which are 100% guaranteed by the SBA.
Data from the application, including the 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.
8. The PPP loan proceeds must be used by the business on certain
permissible expenses—^payroll costs, interest on mortgages, rent, and utihties. The
PPP allows the interest and principal of the PPP loan to be entirely forgiven if the
business spends the loan proceeds on these expense items within a designated period
of time and uses a certain percentage of the PPP loan proceeds on payroll expenses.
9. Benworth Capital Partners, LLC ("Benworth Capital") was a Licensed
mortgage lender, headquartered in Florida, and was an approved lender authorized
to receive and process PPP applications and supporting documentation, and then
make loans as part of the PPP.
10. At all times relevant to this Indictment, Defendant CAMERON
MILLS, was a resident of Georgia.
COUNT ONE
Bank Fraud
18 U.S.C. § 1344
11. The Grand Jury realleges and incorporates by reference paragraphs 1-
10 above in their entirety as if fully set forth herein.
12. On or about April 25, 2021, defendant CAMERON MILLS submitted,
or caused the submission of, a PPP loan application to Benworth Capital. The loan
application sought $20,833 and fraudulently represented that Defendant was the sole
Case 1:22-cr-00042-JRH-BKE Document 1 Filed 05/10/22 Page 4 of 7
proprietor of a business that had $100,000 of gross income in 2019.
13. On or about April 25, 2021, in Richmond County, within the Southern
District of Georgia, and elsewhere, defendant,
CAMERON MILLS,
knowingly executed and attempted to execute a scheme and artifice to defiraud
Benworth Capital and to obtain moneys,funds, assets, and other property owned by,
and under the custody and control of Benworth Capital by means of materially false
and fraudulent pretenses, representations, and promises, to wit, false and fi*audulent
representations concerning the gross income of the business he purported to own.
All done in violation of 18 U.S.C. § 1344.
COUNT TWO
False Statement on a Loan Application
18 U.S.C. § 1014
14. The Grand Jury realleges and incorporates by reference paragraphs 1-
10 above in their entirety as iffuUy set forth herein.
15. On or about April 25, 2021, in Richmond County, within the Southern
District of Georgia, and elsewhere, defendant,
CAMERON MILLS,
did knowingly make, or caused to be made, a false statement for the purpose of
influencing the action of Benworth Capital, a mortgage lending business, in
connection with his PPP loan application, when he submitted, or caused to be
submitted, a loan application falsely representing that Defendant's business had
$100,000 in gross income in 2019, when in truth and in fact, as Defendant well knew,
Case 1:22-cr-00042-JRH-BKE Document 1 Filed 05/10/22 Page 5 of 7
his purported business did not accrue that amount of gross income in 2019.
All in violation ofTitle 18, United States Code, Section 1014.
COUNT THREE
Wire Fraud
18 U.S.C. § 1343
16. The Grand Jury realleges and incorporates by reference paragraphs 1-
10 above in their entirety as if fully set forth herein.
17. In or about April 2021, in Richmond County, within the Southern
District of Georgia, and elsewhere,the defendant, CAMERON MILLS did knowingly
devise and intend to devise a scheme and artifice to defi:aud, and to obtain money and
property, by means of materially false and firaudulent pretenses, representations, and
promises.
18. Defendant's scheme was to unjustly enrich himself by obtaining PPP
proceeds under false and misleading pretenses, including by making false statements
in a PPP application.
19. It was part of the scheme and artifice that Defendant, then residing in
the Southern District of Georgia, caused to be submitted a PPP loan application that
contained false statements about a company he purported to own. In particular, on
or about April 25, 2021, Defendant caused to be submitted an electronic PPP loan
application to Benworth Capital seeking $20,833. Such application falsely affirmed,
among other information, that Defendant's business had $100,000 in gross income in
2019. Defendant knew these assertions to be false.
20. In reliance on false representations made in Defendant's PPP
application, Benworth Capital, headquartered in Florida, approved the requested
Case 1:22-cr-00042-JRH-BKE Document 1 Filed 05/10/22 Page 6 of 7
loan for $20,833 on April 28, 2021 and deposited money into Defendant's bank
account, and Defendant thereafter attempted to access some of these funds in
Georgia.
21. On or about April 25, 2021, in the Southern District of Georgia, and
elsewhere, CAMERON MILLS,for the purpose of executing the scheme and artifice
described above, caused to be transmitted in interstate commerce, by means of a wire
communication, certain signs, signals, and sounds: that is, Defendant CAMERON
MILLS, caused to be transmitted an electronic PPP application fi:om the Southern
District of Georgia to Benworth Capital in Florida, which caused Benworth Capital
to deposit $20,833.00 into Defendant's account at South State Bank, headquartered
in South Carohna.
All in violation of Title 18, United States Code, Section 1343.
Case 1:22-cr-00042-JRH-BKE Document 1 Filed 05/10/22 Page 7 of 7
rp "D:!!
Foreperson
David H. Estes Chris Hovard
United States Attorney Assistant United States Attorney
*Lead Counsel
Patricia G. Rhodes
Assistant United States Attorney
Chief, Criminal Division
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