Indictment — United States v. Natasha Ann Opsal, Eastern District of Washington (ECF No. 1)

Summary

A grand jury indictment in United States v. Natasha Ann Opsal, 2:22-CR-53-TOR, in the United States District Court for the Eastern District of Washington, filed May 3, 2022 as ECF No. 1. It charges wire fraud under 18 U.S.C. § 1343 (Counts 1, 2, 3, 4, 5, 6) and false, fictitious or fraudulent claims under 18 U.S.C. § 287 (Counts 7, 8, 9). The indictment alleges that from on or about April 4, 2020 through at least July 25, 2021, Opsal applied for three PPP loans and eight EIDLs using false information about a purported company, Rusty Bumper Mobile Detailing, including false establishment dates, employee counts and revenue. The forfeiture allegations seek a money judgment of $53,747.00, and the signature block names United States Attorney Vanessa R. Waldref.

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Case 2:22-cr-00053-TOR ECF No. 1

Vanessa R. Waldref

United States Attorney
Eastern District of Washington
Frieda K. Zimmerman

Special Assistant United States Attorney

Tyler H.L. Tornabene

Assistant United States Attorney
Post Office Box 1494

Spokane, WA 99210-1494
Telephone: (509) 353-2767

filed 05/03/22

PagelD.1 Page 1 of 17

UNITED STATES DISTRICT COURT
FOR THE EASTERN DISTRICT OF WASHINGTON

UNITED STATES OF AMERICA,
Plaintiff,
V.
NATASHA ANN OPSAL,

Defendant.

The Grand Jury charges:

2:22-CR-53-TOR

INDICTMENT

Vio:

18 U.S.C. § 1343
Wire Fraud
(Counts 1, 2, 3, 4, 5, 6)

18 U.S.C. § 287
False, Fictitious, or Fraudulent

Claims
(Counts 7, 8, 9)

18 U.S.C. § 981, 28 U.S.C. §
2461
Forfeiture Allegations

GENERAL ALLEGATIONS

1. At all times relevant to this Indictment, the Defendant, NATASHA
ANN OPSAL was a resident of Spokane, Washington.

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2. The Coronavirus Aid, Relief, and Economic Security Act (““CARES”
Act) was a federal law enacted on March 27, 2020, designed to provide emergency
financial assistance to the millions of Americans who were suffering the economic
effects caused by the COVID-19 pandemic. One source of relief provided by the
CARES Act was the authorization of forgivable loans to small businesses for job
retention and other certain expenses, through a program referred to as the Paycheck
Protection Program (“PPP”).

3. In order to obtain a PPP loan, a qualifying business was required 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 in order to be eligible to obtain the PPP loan. In the PPP loan
application, the applicant (through its authorized representative) was required to
state, among other things: (a) its average monthly payroll expenses; and (b) its
number of employees. If the applicant had no employees other than the owner, the
applicant was required to provide the gross income amount from a 2019 or 2020
IRS Form 1040, Schedule C. These figures were used to calculate the amount of
money the small business was eligible to receive under the PPP. Additionally, the
application was required to certify that they were in operation as of February 15,
2020. The applicant was also required to certify that the information in the
application was true and correct to the best of the applicant’s knowledge.

4. A business’s PPP loan application was received and processed, in the
first instance, by a participating lender. If a PPP loan application was approved, the
participating lender funded the PPP loan using its own monies. Data from the
application, including information about the borrower, the total amount of the loan,

the listed number of employees, and the gross income amount, was transmitted by

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the lender to the Small Business Administration (“SBA”), an agency of the United
States, in the course of processing the loan.

5. PPP applications are received in cloud-based platforms. The location
of the server through which the PPP application is submitted is based on the date
the application was processed by the SBA and the application number. During the
time period relevant to this Indictment, all PPP applications were received through
the Summit platform, a cloud-based platform utilizing the AWS GOV cloud
servers located in Oregon. PPP lenders submitted disbursement details into the
SBA E-Tran system in Sterling, Virginia. E-Tran transmitted the PPP processing
fee to the lender through the FMS system to the Treasury. The primary server for
FMS is in Sterling, Virginia.

6. In addition to the PPP loan program, the CARES act also authorized
the Economic Injury Disaster Loan (“EIDL”) program. EIDL is a SBA program
that provides low-interest funding to small businesses, renters, and homeowners
affected by declared disasters.

7. In order to obtain an EIDL and advance, a qualifying business must
submit an application to the SBA and provide information about its operations,
such as the number of employees, gross revenues for the 12-month period
preceding the disaster, and cost of goods sold in the 12-month period preceding the
disaster. In the case of EIDLs for COVID-19 relief, the 12-month period was the
year preceding January 31, 2020. The applicant must also certify that all the
information in the application is true and correct to the best of the applicant’s
knowledge.

8. The amount of an FIDL, if the application is approved, is determined
based, in part, on the information provided in the application about employment,
revenue, and cost of goods, as set forth above. Any funds issued under an EIDL or

advance are issued directly by the SBA. EIDL funds can be used for payroll

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expenses, sick leave, production costs, and business obligations, such as debts,
rent, and mortgage payments. If the applicant also obtains a loan under the
Paycheck Protection Program, the EIDL funds cannot be used for the same purpose
as the Paycheck Protection Program funds.

9. EJDL applications are received in cloud-based platforms. The
location of the server through which the EIDL application is submitted is based on
the date the application was processed by SBA and the application number.

During the time period relevant to this Indictment, all ELDL applications were
received in a Microsoft cloud-based platform using a Rapid Finance application,
through SBA servers located in Des Moines, Iowa.

The Scheme

10. The allegations in paragraphs 1 through 9 of this Indictment are
incorporated as though realleged herein.

11. Beginning no later than on or about April 4, 2020, and continuing
through at least July 25, 2021, in the Eastern District of Washington and elsewhere,
Defendant NATASHA ANN OPSAL devised and intended to devise a scheme to
defraud the SBA, and to obtain money and property by means of materially false and
fraudulent pretenses, representations, and promises.

12. Specifically, Defendant NATASHA ANN OPSAL, applied for and
received three PPP loans using false information about her purported company,
Rusty Bumper Mobile Detailing, with the intent to defraud, steal, and convert the
proceeds of the PPP Loans for Defendant NATASHA ANN OPSAL’s personal use
and without any intent to use the proceeds thereof for any authorized purpose, or any
intent to repay the PPP Loans.

13. Additionally, Defendant NATASHA ANN OPSAL, applied for eight
EIDLs using false information about her purported company, Rusty Bumper Mobile
Detailing, with the intent to defraud, steal, and convert the proceeds of the EIDLs

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for Defendant NATASHA ANN OPSAL’s personal use and without any intent to
use the proceeds thereof for any authorized purpose, or any intent to repay the
EIDLs.

Manner and Means

It was part of this scheme that:

14. On or about April 4, 2020, Defendant NATASHA ANN OPSAL
applied for an EIDL by submitting application number 3302212935 to the SBA
under the name of her purported business, Rusty Bumper Mobile Detailing.
Defendant NATASHA ANN OPSAL listed Rusty Bumper Mobile Detailing’s
business address.as the personal address on her Idaho State Driver’s License.

15. Defendant NATASHA ANN OPSAL falsely stated in application
number 3302212935 that Rusty Bumper Mobile Detailing had been established on
July 15, 2018, that it had 1 employee as of January 1, 2020, and that its 2019 gross
revenue was $10,000. Defendant NATASHA ANN OPSAL indicated that the
Federal Tax ID was XX-XXX-1201, which is Defendant NATASHA ANN
OPSAL’s social security number.

16. Onor about June 7, 2020, Defendant NATASHA ANN OPSAL
applied for an EIDL by submitting application number 3304335795 to the SBA
under the name of her purported business, Rusty Bumper Mobile Detailing.
Defendant NATASHA ANN OPSAL listed the “business address” of the purported
business as her residential address in Spokane, Washington, but with her apartment
number omitted.

17. Defendant NATASHA ANN OPSAL falsely stated in application
number 3304335795 that Rusty Bumper Mobile Detailing had been established on
September 15, 2015, that it had 1 employee as of January 1, 2020, and that its 2019
gross revenue was $40,000. Defendant NATASHA ANN OPSAL indicated that

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the Federal Tax ID was XX-XXX-1201, which is Defendant NATASHA ANN
OPSAL’s social security number.

18. On November 6, 2020, Defendant NATASHA ANN OPSAL applied
for and was assigned Employee Identification Number (EIN) 85-3786210 for
Rusty Bumper Mobile Detailing. EINs are assigned by the IRS on a business by
business basis, and are uniquely formulated numbers that do not mirror the
requestor’s social security number.

19. On or about November 18, 2020, Defendant NATASHA ANN
OPSAL applied for an EIDL by submitting application number 3315328537 to the
SBA as Natasha Opsal DBA Rusty Bumper Mobile Detailing. Defendant
NATASHA ANN OPSAL listed the “business address” of the purported business
as 7911 N. Shenandoah Ct., Spokane, Washington.

20. Defendant NATASHA ANN OPSAL falsely stated in application
number 3315328537 that Rusty Bumper Mobile Detailing had been established on
January 11, 2019, that it had 2 employees as of January 1, 2020, and that its 2019
gross revenue was $25,000. Defendant NATASHA ANN OPSAL indicated that
the Federal Tax ID was 85-3786210.

21. Onor about December 14, 2020, Defendant NATASHA ANN
OPSAL applied for an EIDL by submitting application number 3315589394 to the
SBA as Natasha Opsal DBA Rusty Bumper Mobile Detailing. Defendant
NATASHA ANN OPSAL listed the “business address” of the purported business
as 7911 N. Shenandoah, Spokane, Washington.

22. Defendant NATASHA ANN OPSAL falsely stated in application
number 3315589394 that Rusty Bumper Mobile Detailing had been established on
June 2, 2015, that it had 1 employee as of January 1, 2020, and that its 2019 gross
revenue was $45,000. Defendant NATASHA ANN OPSAL indicated that the

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Federal Tax ID was XX-XXX-1201, which is Defendant NATASHA ANN
OPSAL’s social security number.

23. On or about January 1, 2021, Defendant NATASHA ANN OPSAL
applied for an EIDL by submitting application number 3315945863 to the SBA as
Natasha Opsal DBA Rusty Bumper Mobile Detailing. Defendant NATASHA
ANN OPSAL listed the “business address” of the purported business as 7914 N.
Shenandoah Ave., Spokane, Washington.

24. Defendant NATASHA ANN OPSAL falsely stated in application
number 3315945863 that Rusty Bumper Mobile Detailing had been established on
June 15, 2019, that it had 1 employee as of January 1, 2020, and that its 2019 gross
revenue was $35,000. Defendant NATASHA ANN OPSAL indicated that the
Federal Tax ID was XX-XXX-1201, which is Defendant NATASHA ANN
OPSAL’s social security number.

25. ‘On or about January 1, 2021, Defendant NATASHA ANN OPSAL
applied for an EJDL by submitting application number 3315946665 to the SBA as
Natasha Opsal DBA Rusty Bumper Mobile Detailing. Defendant NATASHA
ANN OPSAL listed the “business address” of the purported business as 7914 N.
Shenandoah, Spokane, Washington.

26. Defendant NATASHA ANN OPSAL falsely stated in application
number 3315946665 that Rusty Bumper Mobile Detailing had been established on
June 15, 2019, that it had 1 employee as of January 1, 2020, and that its 2019 gross
revenue was $3,500. Defendant NATASHA ANN OPSAL indicated that the
Federal Tax ID was XX-XXX-1201, which is Defendant NATASHA ANN
OPSAL’s social security number.

27. Onor about March 11, 2021, Defendant NATASHA ANN OPSAL
submitted PPP Loan application number 26776140 to SBA listing “Natasha Opsal”
as the Business Legal Name and listing “Rusty Bumber detailing” [sic] as the DBA

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or Tradename. In the application, Defendant NATASHA ANN OPSAL listed the
“business address” of the purported business as her residential address in Spokane,
Washington.

28. On application number 26776140, Defendant NATASHA ANN
OPSAL falsely stated that the business was established in 2019, had 1 employee,
and had gross income of $82,000 in tax year 2020. Defendant NATASHA ANN
OPSAL also certified that the business was in operation on February 15, 2020.
Defendant NATASHA ANN OPSAL indicated that Tax Identification Number for
Natasha Opsal DBA Rusty Bumper was XX-XXX-1201, which is Defendant
NATASHA ANN OPSAL’s social security number. This application was
submitted through the Summit platform, a cloud-based platform utilizing the AWS
GOV cloud servers located in Oregon. .

29. On application number 26776140, Defendant NATASHA ANN
OPSAL certified that the information in the application was true and accurate,
subject to criminal penalties for knowingly making false statements.

30. The representations and certifications made by Defendant NATASHA

|| ANN OPSAL on application number 26776140 were materially false, and

Defendant NATASHA ANN OPSAL knew they were false at the time they were
made. In fact, Rusty Bumper Detailing was not created in 2019, and was not a
legitimate existing business at the time of Defendant NATASHA ANN OPSAL’s
PPP application. Moreover, Rusty Bumper Detailing did not have any employees,
did not exist as of February 15, 2020, and did not have any income in tax year
2020. Accordingly, Rusty Bumper Detailing and Defendant NATASHA ANN
OPSAL were not eligible for any PPP funding.

31. Using the above materially false information on application number
26776140, Defendant NATASHA ANN OPSAL applied for a PPP loan of
$17,082.00 through lender Capital Plus Financial, LLC. As a result of the fraud

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and relying on the materially false and fraudulent representations and certifications
made by Defendant NATASHA ANN OPSAL, on or about March 13, 2021, the
lender funded Defendant NATASHA ANN OPSAL’s PPP loan for $17,082.00.
The SBA assigned PPP loan number 19556486-01.

32. PPP loan number 19556486-01 was handled by Capital Plus
Financial, LLC, a community development financial institution based out of
Bedford, Texas, on a delegated basis from the SBA. Capital Plus Financial, LLC,
submitted disbursement details for this loan into the SBA E-Tran system located in
Sterling, Virginia.

33. On March 24, 2021, as a result of the fraudulent scheme described
above, and the materially false and fraudulent information supplied by Defendant
NATASHA ANN OPSAL in application number 26776140, Capital Plus
Financial, LLC, disbursed $17,082.00 to Defendant NATASHA ANN OPSAL’s
Spokane, Washington, Chime Account ending in 6756 for PPP loan number
19556486-01.

34. On or about April 2, 2021, Defendant NATASHA ANN OPSAL
applied for an EIDL by submitting application number 3318122105 to the SBA as
Natasha Opsal DBA Rusty Bumpet [sic]. Defendant NATASHA ANN OPSAL
listed the “business address” of the purported business as her residential address in
Spokane, Washington.

35. Defendant NATASHA ANN OPSAL falsely stated in application
number 3318122105 that her purported business had been established on January
5, 2019, and that its 2019 gross revenue was $83,000. Defendant NATASHA
ANN OPSAL indicated that the Federal Tax ID was XX-XXX-1201, which is
Defendant NATASHA ANN OPSAL’s social security number.

36. Onor about April 12, 2021, Defendant NATASHA ANN OPSAL
submitted PPP Loan application number 29293039 to SBA listing “rusty bumper

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mobile detailing” as the Business Legal Name. In the application, Defendant
NATASHA ANN OPSAL listed the “business address” of the purported business
as 7911 N. Shenandoah Ct., Spokane, Washington.

37. On application number 29293039, Defendant NATASHA ANN
OPSAL falsely stated that the business was established in 2020, had one employee,
and had gross income of $93,000 in tax year 2020. Defendant NATASHA ANN
OPSAL also certified that the business was in operation on February 15, 2020. |
Defendant NATASHA ANN OPSAL indicated that the Tax Identification Number
for Rusty Bumper Mobile Detailing was 85-3786210. This application was
submitted through the Summit platform, a cloud-based platform located in Oregon.

38. On application number 29293039, Defendant NATASHA ANN
OPSAL certified that the information in the application was true and accurate,
subject to criminal penalties for knowingly making false statements.

39. The representations and certifications made by Defendant NATASHA
ANN OPSAL on application number 29293039 were materially false, and
Defendant NATASHA ANN OPSAL knew they were false at the time they were
made. In fact, Rusty Bumper Mobile Detailing was not created in 2020, and was
not a legitimate existing business at the time of Defendant NATASHA ANN
OPSAL’s PPP application. Moreover, Rusty Bumper Mobile Detailing did not
have any employees, and did not exist as of February 15, 2020, nor did it have any
income in tax year 2020. Accordingly, Rusty Bumper Mobile Detailing was not
eligible for any PPP funding.

40. Using the above materially false information on application number
29293039, Defendant NATASHA ANN OPSAL applied for a PPP loan of
$19,375.00. As a result of the fraud and relying on the materially false and
fraudulent representations and certifications made by Defendant NATASHA ANN
OPSAL, on or about April 22, 2021, the lender funded Defendant NATASHA

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ANN OPSAL’s PPP loan for $19,375.00. The SBA assigned PPP loan number
8562388-03.

41. PPP loan number 8562388-03 was handled by Prestamos CDFI, LLC,
a community development financial institution based out of Phoenix, Arizona, on a
delegated basis from the SBA. Prestamos CDFI, LLC, submitted disbursement
details for this loan into the SBA E-Tran system located in Sterling, Virginia.

42. On May 10, 2021, as a result of the fraudulent scheme described -
above, and the materially false and fraudulent information supplied by Defendant
NATASHA ANN OPSAL in application number 29293039, Prestamos CDFI,
LLC, disbursed $19,375.00 to Defendant NATASHA ANN OPSAL’s Spokane,
Washington bank account with Coastal Aspiration ending in 4033 for PPP loan
number 8562388-03.

43. On or about April 29, 2021, Defendant NATASHA ANN OPSAL

submitted-PPP Loan application number 30425393 to SBA listing “Natasha Opsal”

as the Business Legal Name. In the application, Defendant NATASHA ANN
OPSAL listed the “business address” of the purported business as the address of
her residential building in Spokane, Washington, but did not include her apartment
number.

44. On application number 30425393, Defendant NATASHA ANN
OPSAL falsely stated that the business was established in 2020, had one employee,
and had an average monthly payroll cost of $6,916.00. Defendant NATASHA
ANN OPSAL also certified that the business was in operation on February 15,
2020. Defendant NATASHA ANN OPSAL indicated that the Tax Identification
Number was XX-XXX-1201, which is Defendant NATASHA ANN OPSAL’s
social security number. This application was submitted through the Summit
platform, a cloud-based platform utilizing the AWS GOV cloud servers located in
Oregon. On application number 30425393, Defendant NATASHA ANN OPSAL

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certified that the information in the application was true and accurate, subject to
criminal penalties for knowingly making false statements.

45. The representations and certifications made on application number
30425393 by Defendant NATASHA ANN OPSAL were materially false, and
Defendant NATASHA ANN OPSAL knew they were false at the time they were
made. In fact, the business “Natasha Opsal” was not created in 2020 and was not a
legitimate existing business at the time of Defendant NATASHA ANN OPSAL’s
PPP application. Moreover, the business “Natasha Opsal” did not have any
employees, and did not exist as of February 15, 2020, nor did it have any income in
tax year 2020. Accordingly, the business “Natasha Opsal” was not eligible for any
PPP funding.

46. Using the above materially false information in application number
30425393, Defendant NATASHA ANN OPSAL applied for a PPP loan of
$17,290.00. As a result of the fraud and relying on the materially false and
fraudulent representations and certifications made by Defendant NATASHA ANN
OPSAL, on or about May 12, 2021, the lender funded Defendant NATASHA ANN
OPSAL’s PPP loan for $17,290.00. The SBA assigned PPP loan number
96194189-04.

47, PPP loan number 96194189-04 was handled by Prestamos CDFI,
LLC, a community development financial institution based out of Phoenix,
Arizona, on a delegated basis from the SBA. Prestamos CDFI, LLC, submitted
disbursement details for this loan into the SBA E-Tran system located in Sterling,
Virginia.

48. On May 23, 2021, as a result of the fraudulent scheme described
above, and the materially false and fraudulent information supplied by Defendant
NATASHA ANN OPSAL in application number 30425393, Prestamos CDFI,
LLC, disbursed $17,290.00 to Defendant NATASHA ANN OPSAL’s Spokane,

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Washington, bank account with Choice Financial Group ending in 2899 for PPP
loan number 96194189-04. At the time of disbursement of this PPP Loan, the
Choice Financial Group Account held less than a dollar.

49. Onor about July 25, 2021, Defendant NATASHA ANN OPSAL
applied for an EIDL by submitting application number 3322759926 to the SBA
under the name of her purported business, Rusty Bumper Mobile Detailing.
Defendant NATASHA ANN OPSAL listed the “business address” of the purported
business as 7911 N. Shenandoah, Spokane, Washington. |

50. Defendant NATASHA ANN OPSAL falsely stated in application
number 3322759926 that her purported business had been established on May 6,
2018, and that its 2019 gross revenue was $90,000. Defendant NATASHA ANN
OPSAL indicated that the Federal Tax ID was 85-3786210

51. A table comparing some of the information provided by Defendant

NATASHA ANN OPSAL on various applications is provided below:

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2 March 24, EFT payment from Capital Plus Financial, LLC, in
2021 Bedford, Texas to Chime Account ending in 6756 in
Spokane, Washington, in the amount of $17,082.00 for
PPP Loan No. 19556486-01.
3 April 12, PPP Loan Application No. 29293039, electronically
2021 submitted from the Eastern District of Washington to the

SBA in Oregon.

4 May 10, 2021

EFT payment from Prestamos CDFI, LLC, in Phoenix,
Arizona, to Coastal Aspiration Account ending in 4033
in Spokane Washington, in the amount of $19,375.00 for
PPP Loan No. 8562388-03.

2021

5 April 29,

PPP Loan Application No. 30425393, electronically
submitted from the Eastern District of Washington to the
SBA in Oregon.

6 May 23, 2021

EFT payment from Prestamos CDFI, LLC, in Phoenix,
Arizona, to Choice Financial Group Account ending in
2899 in Spokane Washington, in the amount of
$17,290.00 for PPP Loan No. 93194189-04.

All in violation of 18 U.S.C. § 1343.

Counts 7-9

53. On or about each of the dates set forth below, in the Eastern District

of Washington and elsewhere, the Defendant NATASHA ANN OPSAL, made and

presented to the United States Small Business Administration claims concerning

PPP applications, knowing said claims were false and fraudulent, and knowing the

information submitted was materially false and fraudulent, described below for

each count, each transmission constitution a separate count:

Count | Date

Description

2021

7 March 11,

PPP application number 26776140 in the name of
Natasha Opsal DBA “Rusty Bumber detailing” for an
PPP loan in the amount of $17,082.00.

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8 April 12, PPP application number 29293039 in the name of “rusty
2021 bumper mobile detailing” for an PPP loan in the amount
of $19,375.00.
9 April 29, PPP application number 30425393 in the name of
2021 Natasha Opsal DBA “Natasha Opsal” for an PPP loan in
the amount of $17,290.00.

All in violation of 18 U.S.C. § 287.

NOTICE OF FORFEITURE ALLEGATIONS

The allegations contained in this Indictment are hereby realleged and

incorporated herein by this reference for the purpose of alleging forfeitures.
Pursuant to 18 U.S.C. § 98l(a)(1)(C) and 28 U.S.C. § 2461(c), upon

conviction of an offense in violation of 18 U.S.C. § 1343, as alleged in Counts 1

through 6 of this Indictment, Defendant NATASHA ANN OPSAL shall forfeit to

the United States any property, real or personal, which constitutes or is derived from

proceeds traceable to the offense. The property to be forfeited includes, but is not

limited to, the following:

MONEY JUDGMENT

A sum of money equal to $53,747.00 in United States currency, -
representing the amount of proceeds obtained by Defendant,
NATASHA ANN OPSAL from the wire fraud violations.

If any of the property described above, as the result of any act or omission of
the Defendant, NATASHA ANN OPSAL:

(a)
(b)
(c)
(d)
(e)

cannot be located upon the exercise of due diligence;

has been transferred or sold to, or deposited with, a third party;
has been placed beyond the jurisdiction of the court;

has been substantially diminished in ‘value; or

has been commingled with other property which cannot be divided

without difficulty,

the United States shall be entitled to forfeiture of substitute property pursuant to 21

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U.S.C. § 853(p), as incorporated by 18 U.S.C. § 981(a)(1)(C) and 28 U.S.C.

§ 2461(c).

DATED this 23 day of May 2022.

Vanessa R. Waldref
United States Attorne

Frieda K.’Zighmerman
Special Assistant United States Attorney

Tyler H.L. Tornabene
Assistant United States Attorney

INDICTMENT — 17

A TRUE BILL


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