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Indictment — United States v. Raghavender Reddy Budamala, Central District of California (Document 14)

Summary

An Indictment filed March 8, 2022 as Document 14 in United States v. Raghavender Reddy Budamala, No. 2:22-cr-00077-ODW, in the U.S. District Court for the Central District of California. It alleges that the defendant, as manager of Hayventure LLC, Pioneer LLC and XC International LLC, described as shell companies with no substantial business operations or employees, made false representations on PPP loan applications to Celtic, Radius, Newtek and AEF. It lists PPP loan proceeds of $236,597 for Hayventure, $660,000 for the first Pioneer loan, $660,000 for the second Pioneer loan, $1,592,500 for the first XC International loan and $1,842,500 for the second XC International loan. It charges bank fraud under 18 U.S.C. § 1344(2), wire fraud under 18 U.S.C. § 1343 and transactional money laundering under 18 U.S.C. § 1957, with criminal forfeiture under 18 U.S.C. § 982.

Summary drafted by a model from the text of the original file linked on this page 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

Cite this document

“Indictment — United States v. Raghavender Reddy Budamala, Central District of California (Document 14).” Original at archive.org. Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/indictment-no-2-22-cr-00077-dkt-14-c-d-cal-73988b408b/, SHA-256 53dd09d51626f8e0f0d6f3cfdc8741911db1e4cec95933c8b33695191b38bf36.

Full text

     Case 2:22-cr-00077-ODW Document 14 Filed 03/08/22 Page 1 of 14 Page ID #:49



 1                                                             3/8/2022

 2                                                              VAM




 3

 4

 5

 6

 7

 8                          UNITED STATES DISTRICT COURT

 9                    FOR THE CENTRAL DISTRICT OF CALIFORNIA

10                             November 2021 Grand Jury

11   UNITED STATES OF AMERICA,               CR   2:22-cr-00077-ODW

12             Plaintiff,                    I N D I C T M E N T

13             v.                            [18 U.S.C. § 1344(2): Bank Fraud;
                                             18 U.S.C. § 1343: Wire Fraud; 18
14   RAGHAVENDER REDDY BUDAMALA,             U.S.C. § 1957: Transactional Money
       aka “Reddy Raghav Budamala,”          Laundering; 18 U.S.C. § 982:
15                                           Criminal Forfeiture]
               Defendant.
16

17        The Grand Jury charges:
18                              COUNTS ONE THROUGH SIX
19                          [18 U.S.C. §§ 1344(2), 2(b)]
20   A.   INTRODUCTORY ALLEGATIONS
21        At times relevant to this Indictment:
22        1.    Defendant RAGHAVENDER REDDY BUDAMALA, also known as “Reddy
23   Raghav Budamala,” resided in Irvine, California.
24        2.    Defendant BUDAMALA was the manager of Hayventure LLC
25   (“Hayventure”), Pioneer LLC (“Pioneer”), and XC International LLC
26   (“XC International”), three shell companies with no substantial
27   business operations or employees.
28
     Case 2:22-cr-00077-ODW Document 14 Filed 03/08/22 Page 2 of 14 Page ID #:50



 1        3.    Celtic Bank (“Celtic”), Radius Bank (“Radius”), Newtek

 2   Small Business Finance (“Newtek”), and Amur Equipment and Finance

 3   (“AEF”) were financial institutions that the Federal Deposit

 4   Insurance Company insured and that were approved Small Business

 5   Administration (“SBA”) lenders.

 6                           Paycheck Protection Program

 7        4.    The Coronavirus Aid, Relief, and Economic Security
 8   (“CARES”) Act was a federal law enacted in March 2020 to provide
 9   emergency financial assistance to the millions of Americans who
10   suffered from the economic consequences of COVID-19.
11        5.    The CARES Act authorized forgivable loans to small
12   businesses for employee retention and certain business expenses
13   through an SBA program called the Paycheck Protection Program (“PPP”
14   or “the program”).
15        6.    The program authorized qualifying small businesses and
16   other organizations to receive loans that the SBA guaranteed and that
17   qualified for loan forgiveness. To qualify for the program, the
18   applicant business had to use the PPP loan proceeds on payroll costs,
19   mortgage interest, rent, and utilities, and must have been operating
20   prior to February 15, 2020.
21        7.    On the PPP loan application, the applicant was required to
22   truthfully state, among other things, the business’s average monthly
23   payroll expenses and number of employees, figures that were used to
24   calculate the amount of loan proceeds the small business was eligible
25   to receive under the program. The applicant business was also
26   required to provide documentation showing its payroll expenses.
27        8.    The SBA administered the program and had authority over the
28   PPP loans. However, approved lenders -- including Celtic, Radius,
                                            2
     Case 2:22-cr-00077-ODW Document 14 Filed 03/08/22 Page 3 of 14 Page ID #:51



 1   Newtek, and AEF -- administered the loans. The approved lenders

 2   received and processed the PPP applications and supporting

 3   documentation, then made the loans using their own funds.

 4   B.   THE SCHEME TO DEFRAUD

 5        9.    Beginning in or about March 2020, and continuing through in
 6   or about February 2022, in Los Angeles and Orange Counties, within
 7   the Central District of California, and elsewhere, defendant
 8   BUDAMALA, together with others known and unknown to the Grand Jury,
 9   knowingly and with intent to defraud, devised, participated in,
10   executed, and attempted to execute a scheme to obtain money and
11   property owned by and in the custody and control of Celtic, Radius,
12   Newtek, AEF, and the SBA by means of material false and fraudulent
13   pretenses, representations, and promises, and the concealment of
14   material facts.
15        10.   The fraudulent scheme operated and was carried out, in
16   substance, as follows:
17                                     Hayventure
18              a.     On or about April 30, 2020, defendant BUDAMALA applied
19   to Celtic for a PPP loan on behalf of Hayventure, stating on the
20   application that he was the sole owner of Hayventure. On the loan
21   application, defendant BUDAMALA falsely represented to Celtic and the
22   SBA, among other things, that Hayventure had 10 employees and monthly
23   payroll of $94,639. In support of the application, defendant BUDAMALA
24   submitted to Celtic a forged bank statement and false Internal
25   Revenue Service (“IRS”) Forms 941 (“Forms 941”).
26              b.     Defendant BUDAMALA caused Celtic to rely on the false
27   representations and certifications defendant BUDAMALA made on the
28   Hayventure PPP loan application, and on or about May 4, 2020, to
                                            3
     Case 2:22-cr-00077-ODW Document 14 Filed 03/08/22 Page 4 of 14 Page ID #:52



 1   credit an Azlo Bank (“Azlo”) account ending in 5756, that defendant

 2   BUDAMALA had opened in the name of Hayventure (“Azlo 5756”), with

 3   $236,597 in PPP loan proceeds.

 4                c.   On or about September 14, 2021, defendant BUDAMALA

 5   applied to Celtic and the SBA to have the Hayventure PPP loan

 6   forgiven. On the forgiveness application, defendant BUDAMALA falsely

 7   represented, among other things, that Hayventure had 10 employees at

 8   the time of the forgiveness application, and that Hayventure used all

 9   of the PPP loan proceeds on payroll costs. In support of the

10   forgiveness application, defendant BUDAMALA submitted to Celtic false

11   documents including false payroll summaries.

12                                       Pioneer

13                d.   On or about June 4, 2020, defendant BUDAMALA acquired
14   Pioneer, a shell company with no substantial business operations or
15   employees.
16                e.   On or about June 10, 2020, defendant BUDAMALA applied
17   to Radius for a PPP loan on behalf of Pioneer (“the first Pioneer
18   loan”). On the first Pioneer loan application, defendant BUDAMALA
19   falsely represented to Radius and the SBA, among other things, that
20   Pioneer had 33 employees and monthly payroll of $264,000. In support
21   of the first Pioneer loan application, defendant BUDAMALA submitted
22   to Radius false documents, including false Forms 941.
23                f.   Defendant BUDAMALA caused Radius to rely on the false
24   representations and certifications defendant BUDAMALA made on the
25   first Pioneer loan application and, on or about June 24, 2020, to
26   credit an Azlo account ending in 7635, that defendant BUDAMALA had
27   opened in the name of Pioneer (“Azlo 7635”), with $660,000 in PPP
28   loan proceeds.
                                            4
     Case 2:22-cr-00077-ODW Document 14 Filed 03/08/22 Page 5 of 14 Page ID #:53



 1              g.    On or about October 7, 2020, defendant BUDAMALA

 2   applied to Radius and the SBA to have the first Pioneer loan

 3   forgiven. On the forgiveness application, defendant BUDAMALA falsely

 4   represented, among other things, that Pioneer had 33 employees at the

 5   time of both the loan and forgiveness applications, and that Pioneer

 6   used all of the PPP loan proceeds on payroll costs. In support of the

 7   forgiveness application, defendant BUDAMALA submitted to Radius false

 8   payroll summaries, a false Form 941, and false profit and loss

 9   statements.

10              h.    On or about January 20, 2021, defendant BUDAMALA

11   applied to Radius for a second PPP loan on behalf of Pioneer (“the

12   second Pioneer loan”). On the second Pioneer loan application,

13   defendant BUDAMALA falsely represented to Radius and the SBA, among

14   other things, that Pioneer had 33 employees and monthly payroll

15   expenses of $264,000. In support of the second Pioneer loan

16   application, defendant BUDAMALA submitted to Radius a forged letter

17   from Azlo, a false Form 941, and false payroll summaries.

18              i.    Defendant BUDAMALA caused Radius to rely on the false

19   representations and certifications defendant BUDAMALA made on the

20   second Pioneer loan application and, on or about March 3, 2021, to

21   credit Azlo 7635 with $660,000 in PPP loan proceeds.

22                                 XC International

23              j.    On or about August 6, 2020, defendant BUDAMALA applied
24   to Newtek for a PPP loan on behalf of XC International (“the first XC
25   International loan”). On the first XC International loan application,
26   defendant BUDAMALA falsely represented to Radius and the SBA, among
27   other things, that XC International had 42 employees and monthly
28   payroll of $637,000. In support of the first XC International loan
                                            5
     Case 2:22-cr-00077-ODW Document 14 Filed 03/08/22 Page 6 of 14 Page ID #:54



 1   application, defendant BUDAMALA submitted to Newtek a forged letter

 2   from Azlo, a false Form 941, and false payroll summaries.

 3              k.    Defendant BUDAMALA caused Newtek to rely on defendant

 4   BUDAMALA’s false representations and certifications on the first XC

 5   International loan application, and on or about August 10, 2020, to

 6   credit Azlo 5756 with $1,592,500 in PPP loan proceeds.

 7              l.    On or about August 10, 2020, four days after he had

 8   applied for the first XC International loan, defendant BUDAMALA

 9   acquired XC International, a shell company with no substantial

10   business operations or employees.

11              m.    On or about February 2, 2021, defendant BUDAMALA

12   applied to Newtek for a second PPP loan on behalf of XC

13   International. On the loan application, defendant BUDAMALA falsely

14   represented to Newtek and the SBA, among other things, that XC

15   International had 42 employees and monthly payroll expenses of

16   $637,000. In support of this application, defendant BUDAMALA

17   submitted to Newtek false documents, including false payroll

18   summaries and false profit and loss statements.

19              n.    On or about March 19, 2021, following Newtek’s denial

20   of XC International’s second PPP loan application, defendant BUDAMALA

21   applied to AEF for a second PPP loan on behalf of XC International

22   (“the second XC International loan”). On the loan application,

23   defendant BUDAMALA falsely represented to AEF and the SBA, among

24   other things, that XC International had 42 employees with an average

25   monthly payroll of $737,000. In support of the application, defendant

26   BUDAMALA submitted to AEF a forged Azlo bank statement, a forged

27   letter from Azlo, and false Forms 941.

28
                                            6
     Case 2:22-cr-00077-ODW Document 14 Filed 03/08/22 Page 7 of 14 Page ID #:55



 1               o.   Defendant BUDAMALA caused AEF to rely on the false

 2   representations and certifications defendant BUDAMALA made on the

 3   second XC International loan application, and on or about March 30,

 4   2021, to credit Azlo 5756 with $1,842,500 in PPP loan proceeds.

 5                    Fraudulent Expenditure of Loan Proceeds

 6               p.   Once Celtic, Radius, Newtek, and AEF funded the PPP
 7   loans to Hayventure, Pioneer, and XC International, defendant
 8   BUDAMALA -- in contravention of his promises on the PPP loan
 9   applications to spend the loan proceeds on supporting those
10   companies’ payroll and operations -- used the SBA loan proceeds for
11   personal expenditures, including to pay for personal retail
12   purchases, living expenses, and personal legal expenses; purchase
13   real estate for investment purposes; and fund investment accounts
14   including, an account at TD Ameritrade, that defendant BUDAMALA held
15   personally.
16 C.      EXECUTIONS OF THE FRAUDULENT SCHEME
17         11.   On or about the following dates, in Los Angeles and Orange
18   Counties, within the Central District of California, and elsewhere,
19   defendant BUDAMALA committed and willfully caused others to commit
20   the following acts, each of which constituted an execution or
21   attempted execution of the fraudulent scheme:
22   COUNT         DATE               ACT
     ONE           4/30/20            Submission of an application for a PPP
23                                    loan to Celtic in the name of Hayventure
                                      (Execution).
24
     TWO           6/10/20            Submission of an application for a PPP
25                                    loan to Radius in the name of Pioneer
                                      (Execution).
26   THREE         8/6/2020           Submission of an application for a PPP
                                      loan to Newtek in the name of XC
27                                    International (Execution).
28
                                            7
     Case 2:22-cr-00077-ODW Document 14 Filed 03/08/22 Page 8 of 14 Page ID #:56



 1   COUNT       DATE                 ACT
     FOUR        1/20/2021            Submission of an application for a PPP
 2                                    loan to Radius in the name of Pioneer
                                      (Execution).
 3

 4   FIVE        2/2/2021             Submission of an application for a PPP
                                      loan to Newtek in the name of XC
 5                                    International (Attempted Execution).
 6   SIX         3/19/2021            Submission of an application for a PPP
                                      loan to AEF in the name of XC
 7
                                      International (Execution).
 8

 9

10

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13

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15

16

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                                            8
     Case 2:22-cr-00077-ODW Document 14 Filed 03/08/22 Page 9 of 14 Page ID #:57



 1                                    COUNT SEVEN

 2                                [18 U.S.C. § 1343]

 3        12.   The Grand Jury realleges paragraphs 1 through 8 and 10 of

 4   this Indictment here.

 5   A.   INTRODUCTORY ALLEGATIONS

 6                     Economic Injury Disaster Loan Program
 7        At times relevant to this Indictment:
 8        13.   An Economic Injury Disaster Loan (“EIDL”) was an SBA-
 9   administered loan program designed to provide assistance to small
10   businesses that suffered substantial economic injury as a result of a
11   declared disaster. An EIDL loan helped businesses meet financial
12   obligations that could have been met had the disaster not occurred.
13   It provided relief from economic injury that the disaster caused and
14   permitted businesses to maintain a reasonable working capital
15   position during the disaster period.
16        14.   In March 2020, due to the COVID-19 pandemic, the SBA issued
17   an Economic Injury Disaster Loan declaration. The declaration made
18   EIDL loans available nationwide to small businesses to help alleviate
19   the economic injury that COVID-19 caused.
20   B.   THE SCHEME TO DEFRAUD
21        15.   Beginning in or about March 2020, and continuing through in
22   or about February 2022, in Los Angeles and Orange Counties, within
23   the Central District of California, and elsewhere, defendant
24   BUDAMALA, together with others known and unknown to the Grand Jury,
25   knowingly and with intent to defraud, devised, participated in, and
26   executed a scheme to defraud the SBA as to material matters, and to
27   obtain moneys, funds, assets, and other property owned by and in the
28   custody and control of the SBA by means of material false and
                                            9
     Case 2:22-cr-00077-ODW Document 14 Filed 03/08/22 Page 10 of 14 Page ID #:58



 1   fraudulent pretenses, representations, and promises, and the

 2   concealment of material facts.

 3         16.   The fraudulent scheme operated and was carried out, in

 4   substance, as follows:

 5               a.   On or about June 18, 2020, defendant BUDAMALA

 6   electronically applied to the SBA for an EIDL loan on behalf of

 7   Hayventure. On the loan application, defendant BUDAMALA falsely

 8   represented to the SBA, among other things, that Hayventure had 13

 9   employees, that Hayventure had $264,000 in monthly payroll expenses,

10   and that he would use the loan proceeds for the operation of

11   Hayventure.

12               b.   Defendant BUDAMALA caused the SBA, through the United

13   States Department of the Treasury, to rely on defendant BUDAMALA’s

14   false representations and certifications in the Hayventure EIDL

15   application, and on or about June 22, 2020, to credit Azlo 5756 with

16   $149,900 in EIDL loan proceeds.

17   C.    USE OF THE WIRES

18         17.   On or about June 18, 2020, in Los Angeles and Orange
19   Counties, within the Central District of California, and elsewhere,
20   for the purpose of executing the above-described scheme to defraud,
21   defendant BUDAMALA transmitted and caused the transmission of an
22   electronic application to the SBA for an EIDL loan on behalf of
23   Hayventure by means of wire and radio communication in interstate
24   commerce.
25

26

27

28
                                            10
     Case 2:22-cr-00077-ODW Document 14 Filed 03/08/22 Page 11 of 14 Page ID #:59



 1                               COUNTS EIGHT THROUGH TEN

 2                               [18 U.S.C. §§ 1957, 2(b)]

 3           18.   The Grand Jury realleges paragraphs 1 through 8, 10, 12,

 4   and 13 of this Indictment here.

 5           19.   On or about the dates set forth below, in Los Angeles and

 6   Orange Counties, within the Central District of California, and

 7   elsewhere, defendant BUDAMALA, knowing that the funds involved

 8   represented the proceeds of some form of unlawful activity, engaged

 9   in and willfully caused others to engage in the following monetary

10   transactions, in criminally derived property of a value greater than

11   $10,000, which property, in fact, was derived from specified unlawful

12   activity, namely, bank fraud, committed in violation of Title 18,

13   United States Code, Section 1344(2), as charged in Counts One through

14   Six of this Indictment, and wire fraud, committed in violation of

15   Title 18, United States Code, Section 1343, as charged in Count Seven

16   of this Indictment:

17    COUNT         DATE               MONETARY TRANSACTION
      EIGHT         03/29/2021         Transfer of $970,000 from a Citibank
18                                     account ending 4850 in the name of
                                       defendant BUDAMALA (“Citibank 4850”) to
19
                                       a First Midwest Bank NA account in the
20                                     name of Company 1.

21    NINE          07/02/2021         Transfer of $578,115 from Citibank 4850
                                       to a Comerica Bank California account in
22                                     the name of Company 2.
23
      TEN           07/27/2021         Transfer of $1,211,487.30 from Citibank
24                                     4850 to a First American Trust FSB
                                       account in the name of Company 3 for a
25                                     real estate investment.

26

27

28
                                            11
     Case 2:22-cr-00077-ODW Document 14 Filed 03/08/22 Page 12 of 14 Page ID #:60



 1                             FORFEITURE ALLEGATION ONE

 2                                 [18 U.S.C. § 982]
 3
           1.   Pursuant to Rule 32.2(a) of the Federal Rules of Criminal
 4
     Procedure, notice is hereby given that the United States of America
 5
     will seek forfeiture as part of any sentence, pursuant to Title 18,
 6
     United States Code, Section 982(a)(2), in the event of the
 7
     defendant’s conviction of the offenses set forth in any of Counts One
 8
     through Seven of this Indictment.
 9
           2.   The defendant, if so convicted, shall forfeit to the United
10
     States of America the following:
11
                (a) All right, title and interest in any and all property,
12
     real or personal, constituting, or derived from, any proceeds
13
     obtained, directly or indirectly, as a result of the offense; and
14
                (b) To the extent such property is not available for
15
     forfeiture, a sum of money equal to the total value of the property
16
     described in subparagraph (a).
17
           3.   Pursuant to Title 21, United States Code, Section 853(p),
18
     as incorporated by Title 18, United States Code, Section 982(b), the
19
     defendant, if so convicted, shall forfeit substitute property, up to
20
     the total value of the property described in the preceding paragraph
21
     if, as the result of any act or omission of the defendant, the
22
     property described in the preceding paragraph, or any portion
23
     thereof: (a) cannot be located upon the exercise of due diligence;
24
     (b) has been transferred, sold to or deposited with a third party;
25
     (c) has been placed beyond the jurisdiction of the court; (d) has
26
     been substantially diminished in value; or (e) has been commingled
27
     with other property that cannot be divided without difficulty.
28
                                            12
     Case 2:22-cr-00077-ODW Document 14 Filed 03/08/22 Page 13 of 14 Page ID #:61



 1                             FORFEITURE ALLEGATION TWO

 2                                 [18 U.S.C. § 982]

 3         1. Pursuant to Rule 32.2(a) of the Federal Rules of Criminal

 4   Procedure, notice is hereby given that the United States will seek

 5   forfeiture as part of any sentence, pursuant to Title 18, United

 6   States Code, Section 982(a)(1), in the event of the defendant’s

 7   conviction of the offenses set forth in any of Counts Eight through

 8   Ten of this Indictment.

 9         2.   The defendant, if so convicted, shall forfeit to the United

10   States of America the following:

11              (a) Any property, real or personal, involved in such

12   offense, and any property traceable to such property; and

13              (b)   To the extent such property is not available for

14   forfeiture, a sum of money equal to the total value of the property

15   described in subparagraph (a).

16         3.   Pursuant to Title 21, United States Code, Section 853(p),

17   as incorporated by Title 18, United States Code, Section 982(b)(1),

18   and Title 18, United States Code, Section 982(b)(2), the defendant,

19   if so convicted, shall forfeit substitute property, if, by any act or

20   omission of the defendant, the property described in the preceding

21   paragraph, or any portion thereof: (a) cannot be located upon the

22   exercise of due diligence; (b) has been transferred, sold to, or

23   deposited with a third party; (c) has been placed beyond the

24   jurisdiction of the court; (d) has been substantially diminished in

25   value; or (e) has been commingled with other property that cannot be

26   divided without difficulty. Substitution of assets shall not be

27   ordered, however, where the convicted defendant acted merely as an

28   intermediary who handled but did not retain the property in the
                                            13
     Case 2:22-cr-00077-ODW Document 14 Filed 03/08/22 Page 14 of 14 Page ID #:62



 1   course of the money laundering offense unless the defendant, in

 2   committing the offense or offenses giving rise to the forfeiture,

 3   conducted three or more separate transactions involving a total of

 4   $100,000.00 or more in any 12-month period.

 5

 6                                               A TRUE BILL
 7

 8
                                                        /S/
                                                 Foreperson
 9

10    TRACY L. WILKISON
      United States Attorney
11

12

13    SCOTT M. GARRINGER
      Assistant United States Attorney
14    Chief, Criminal Division

15    RANEE A. KATZENSTEIN
      Assistant United States Attorney
16    Chief, Major Frauds Section

17    KRISTEN A. WILLIAMS
      Assistant United States Attorney
18    Deputy Chief, Major Frauds Section

19    GREGORY BERNSTEIN
      Assistant United States Attorney
20    Major Frauds Section

21

22

23

24

25

26

27

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                                            14


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