Indictment — United States v. Tod Ray Keilholz, Western District of Missouri (Document 1)

Summary

A grand jury indictment of Tod Ray Keilholz, a/k/a Todd Ray Keilholz, Case No. 2:22-cr-04051-RK, in the U.S. District Court for the Western District of Missouri, filed September 14, 2022 as Document 1. It charges bank fraud under 18 U.S.C. § 1344(1) in Counts 1 through 8, false statements under 18 U.S.C. § 1014 and 18 U.S.C. § 1001(a)(3), aggravated identity theft under 18 U.S.C. § 1028A(a)(1) in Counts 19 through 28, and monetary transactions in Counts 29 through 52. The indictment alleges that Keilholz obtained a $1,706,260.00 PPP loan from US Bank for TRK Construction on false payroll claims, sought a $7,818,705 PPP loan for TRK Valpo that US Bank denied, and used a cashier's check of $3,302,830.61 funded by a TL Builders PPP loan to pay Hawthorn Bank loans. The 26-page indictment includes forfeiture allegations.

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“Indictment — United States v. Tod Ray Keilholz, Western District of Missouri (Document 1).” Original at archive.org. Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/indictment-no-2-22-cr-04051-dkt-1-w-d-mo-350bb82448/, SHA-256 0e42b2fa13468196beba339a83d2f69f3e353c905968c01ea14ac52f61376266.

Full text

IN THE UNITED STATES DISTRICT COURT FOR THE
WESTERN DISTRICT OF MISSOURI
CENTRAL DIVISION

UNITED STATES OF AMERICA, No. 22-cr-04051-RK-01

Plaintiff, COUNTS 1 through 8: 18 U.S.C. § 1344(1)
COUNTS 9 through 14: 18 U.S.C.§ 1014
v. NMT 30 Years Imprisonment
NMT $1,000,000 Fine
TOD RAY KEILHOLZ, NMT 5 Years Supervised Release
a/k/a “Todd Ray Keilholz,” Class B Felony
[DOB: 7/21/1963]
COUNTS 15 through 18
Defendant. 18 U.S.C. § 1001(a)(3)
NMT 5 Years Imprisonment
NMT $250,000 Fine
NMT 3 Years Supervised Release
Class C Felony

COUNTS 19 through 28
18 U.S.C. § 1028A(a)(1)
NMT 2 Years Imprisonment
(Consecutive to other sentence imposed
on Counts 1-18 and 29-52)
NMT $250,000
NMT 1 Year Supervised Release
Class E Felony

COUNTS 29 through 52
18 U.S.C. ' 1957(a)
NMT 10 Years Imprisonment
NMT $500,000
NMT 3 Years Supervised Release
Class C Felony

FORFEITURE ALLEGATION
18 U.S.C. §§ 981(a)(1)(A) and (C) and
982(a)(1) and (2)(A)
28 U.S.C. § 2461(c)

$100 Special Assessment (Each Count)
Mandatory Restitution (Counts 1 through 28)

Case 2:22-cr-04051-RK Document 1 Filed 09/14/22 Page 1 of 26
INDICTMENT

THE GRAND JURY CHARGES THAT:

Introduction and Background

At all times relevant to this Indictment:

The Defendant/Properties/Todd Ray Keilholz Business Entities

1. The defendant, TOD RAY KEILHOLZ, a/k/a “Todd Ray Keilholz,”

(KEILHOLZ), was a resident of the Western District of Missouri, who at various times resided

in the Jefferson City, Columbia, and Kansas City, Missouri areas. KEILHOLZ was the sole

owner of the following entities:

a. TRK Construction, LLC, (TRK Construction) was organized in the State of

Missouri on August 23, 2011. On March 8, 2017, KEILHOLZ changed the business

address to 508 Summerhill Drive, Jefferson, City, Missouri. In a quarterly wage report

filed with the Missouri Division of Employment Security (MDES), TRK Construction

reported the payment of $220,741.09 wages to nine (9) employees from January 1, 2019,

through March 31, 2019. TRK Construction filed no quarterly wage reports with MDES

from April 1, 2019, through September 30, 2020. In a quarterly wage report filed with the

Indiana Department of Workforce Development (IDWD), TRK Construction reported the

payment of $103,099.88 wages to five (5) employees from January 1, 2019, through March

31, 2019. TRK Construction filed no quarterly wage reports with IDWD from April 1,

2019, through September 30, 2020.

b. TRK Valpo, LLC, (TRK Valpo) was organized in the State of Missouri on

February 22, 2017. TRK Valpo filed no quarterly wage reports with MDES from January

Case 2:22-cr-04051-RK Document 1 Filed 09/14/22 Page 2 of 26
1, 2019, through June 30, 2020. In a quarterly wage report filed with MDES for the third

quarter of 2020, TRK Valpo reported the payment of $145,156.02 wages to MDES for four

(4) employees. TRK Valpo filed no quarterly wage reports with IDWD from January 1,

2019, through June 30, 2020. In a quarterly wage report filed with IDWD for the third

quarter of 2020, TRK Valpo reported the payment of $85,264.54 wages for five (5)

employees.

c. TL Builders, LLC, (TL Builders) was organized in the State of Missouri on

July 21, 2007. On March 28, 2018, KEILHOLZ changed the business address to 508

Summerhill Drive, Jefferson City, Missouri. TL Builders filed no quarterly wage reports

with MDES from January 1, 2019, through September 30, 2020. TL Builders filed no

quarterly wage reports with IDWD from January 1, 2019, through September 30, 2020.

d. Project Design, LLC, (Project Design) was organized in the State of Indiana

on November 15, 2018, with a principal business address of 1290 Arrowhead Court, Crown

Point, Indiana. On February 5, 2019, KEILHOLZ changed the principal address for

Project Design to 2005 West Broadway, Suite 100, Columbia, Missouri 65203. Project

Design filed no quarterly wage reports with MDES from January 1, 2019, through

September 30, 2020. Project Design filed no quarterly wage reports with IDWD from

January 1, 2019, through September 30, 2020.

2. In Small Business Administration (SBA) Paycheck Protection Program (PPP) loan

applications, KEILHOLZ identified his wife as an employee of TRK Construction, TRK Valpo,

and Project Design, while KEILHOLZ’ wife worked as a full-time employee of the State of

Missouri as a budget analyst with annual salaries ranging from $35,952.00 to $52,337.00. In 2017

Case 2:22-cr-04051-RK Document 1 Filed 09/14/22 Page 3 of 26
and 2018, KEILHOLZ’ wife personally guaranteed commercial loans made to TRK Construction,

LLC. Between February 21, 2019, and May 9, 2020, KEILHOLZ’ wife wrote personal checks

identified as “loan,” “investment,” “Valpo Investment,” and “interest on home loan” in the

aggregate amount of $216,350.00 to TRK Construction and Project Design. Between May 2020

and December 2020, KEILHOLZ’ wife received business checks from TRK Construction, TRK

Valpo, and Project Design funded with PPP loan proceeds in the aggregate amount of $325,000.00

and denominated as “loan repayments.”

3. Prior to March 27, 2020, KEILHOLZ through TRK Construction had accrued

substantial and delinquent indebtedness to American Express, JP Morgan Chase, Citibank, N.A.,

NWI Medical Realty, LLC, Bell Hospital Systems, the Kansas City Chiefs Football Club, Renal

Treatment Centers-Mid Atlantic, Inc., DVA Renal Healthcare, Inc., Renal Treatment Centers-

Illinois, Inc., Total Renal Care, Inc., Adams Masonry, C&C Iron, Inc., C&S Concrete

Construction, Inc., Circle R Mechanical, Inc., Emcor-Hyre Electric Company of Indiana, Gluth

Brothers Roofing Company, Inc., Imboden Construction, Inc., McAllister Leasing & Excavating,

Inc., Trout Glass and Mirror, Inc., Kleckner Interior Systems, Inc., Master Tile Carpet One, Inc.,

Ryan Fire Protection, Inc., and Hawthorn Bank. All or part of these debts were satisfied by PPP

loan proceeds.

Hawthorn Bank

4. Hawthorn Bank was a financial institution headquartered in Jefferson City,

Missouri. The deposits of Hawthorn Bank were insured by the Federal Deposit Insurance

Corporation (FDIC), under certificate number 10619. Hawthorn Bank maintained a long-term

Case 2:22-cr-04051-RK Document 1 Filed 09/14/22 Page 4 of 26
banking relationship with business entities controlled by KEILHOLZ. After March 27, 2020,

Hawthorn Bank participated in the SBA’s PPP.

5. On or about August 31, 2017, KEILHOLZ signed Hawthorn Bank promissory

note 101010203 in the amount of $550,000.00 for TRK Valpo, which financed the purchase of

and was secured by the real property located at 1425 Glendale, Valparaiso, Indiana. This loan

originally matured on October 15, 2017; however, the maturity date on this loan was extended six

times between October 2017 and December 2019, when the maturity date was then extended to

February 5, 2020.

6. On or about January 24, 2018, KEILHOLZ signed Hawthorn Bank promissory

note 101011285 in the amount of $1,001,020.00 for TRK Construction as a line of credit secured

by the real property located at 1425 Glendale, Valparaiso, Indiana. KEILHOLZ and his wife

each personally guaranteed this loan, which was originally to mature on January 24, 2019. On

February 27, 2018, this line of credit was increased to $1,500,000.00 and the maturity date was

extended. On April 27, 2018, this line of credit was increased to $2,000,000.00 and the maturity

date was extended. Finally, in December 2019, the maturity date was extended to February 5,

2020.

7. On or about September 21, 2018, KEILHOLZ signed a Hawthorn Bank

promissory note 101011737 in the amount of $976,771.00 for TRK Construction as a line of credit

secured by real properties located at 508 Summerhill Drive, Jefferson City, Missouri, and 3311

Shamrock Drive, Jefferson City, Missouri, and 1425 Glendale, Valparaiso, Indiana. To obtain this

line of credit, KEILHOLZ submitted a document that purported to be his 2017 IRS Form 1040,

which materially misstated his income and was never filed with the IRS. KEILHOLZ and his

Case 2:22-cr-04051-RK Document 1 Filed 09/14/22 Page 5 of 26
wife each personally guaranteed this loan, which originally was to mature on March 21, 2019. The

maturity date of this loan was extended three times during 2019, with a maturity date of February

5, 2020, that was established in December 2019.

8. On or about February 7, 2020, the Hawthorn Bank loan officer responsible for

Hawthorn Bank loans 101010203, 101011285, and 101011737, wrote a memorandum to those

loan files regarding a phone conference with KEILHOLZ. That memorandum stated, in part, as

follows, “The Bank indicated he needed to bring the loans current and demonstrate that the project

remains viable or the bank would move forward with aggressive collection or liquidation of

collateral.”

9. On February 12, 2020, at approximately 9:56 a.m., KEILHOLZ sent an e-mail to

his Hawthorn Bank loan officer, which made the following materially false statements: “Once we

have the issue with City taken care of the investors are ready to move forward,” and “The lease

with be this month or first of next and being finalized. The lease wants to see us moving again to

make sure we make next year’s deadline for them to move in.”

10. On or about April 28, 2020, Hawthorn Bank entered into a forbearance agreement

with TRK Construction and TRK Valpo, and with KEILHOLZ and his wife as guarantors of

Hawthorn Bank loans 101010203, 101011285, and 101011737. Among other things, this

forbearance agreement:

a. Extended the maturity dates of Hawthorn Bank loans 101010203,

101011285, and 101011737, to July 25, 2020;

b. Required monthly payments of $25,000.00 to Hawthorn Bank May 20,

2020, June 20, 2020, and July 20, 2020, on loans 101010203, 101011285, and 101011737;

Case 2:22-cr-04051-RK Document 1 Filed 09/14/22 Page 6 of 26
c. Required TRK Construction and TRK Valpo, and KEILHOLZ and his

wife as guarantors, to immediately take action to correct and cure any violations of any city

ordinances, codes, rules, regulations, and/or statutes with respect to any governmental

agency of the City of Valparaiso, Indiana, and the State of Indiana;

d. Required TRK Construction and TRK Valpo, and KEILHOLZ and his

wife as guarantors, to take action to ensure that their suppliers, laborers, materialmen, or

other vendors do not file or record any mechanics liens, or similar liens or encumbrances,

with respect to 1425 Glendale Boulevard, Valparaiso, Indiana; and,

e. Required TRK Construction and TRK Valpo, and KEILHOLZ and his

wife as guarantors, to provide Hawthorn Bank with weekly reports, photographs, and status

updates on all construction work with respect to 1425 Glendale Boulevard, Valparaiso,

Indiana, or within 24 hours of a request by Hawthorn Bank.

11. On or about July 3, 2020, KEILHOLZ purchased a cashier’s check at U.S. Bank

National Association in the amount of $3,302,830.61 payable to TRK Construction. This cashier’s

check was deposited into Hawthorn Bank account ending in 1523 and then applied to the

outstanding balances on Hawthorn Bank loans 101010203, 101011285, and 101011737. This

cashier’s check was funded by the proceeds of a PPP loan made to TL Builders.

The Small Business Administration/The CARES Act/Paycheck Protection Program

12. The SBA was an executive branch agency of the United States government that

provided 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. As part of

Case 2:22-cr-04051-RK Document 1 Filed 09/14/22 Page 7 of 26
this effort, the SBA enabled and provided for loans through banks, credit unions and other lenders.

These loans had government-backed guarantees.

13. On March 27, 2020, The CARES Act established several new temporary programs

and provided for the expansion of others to address the COVID-19 pandemic. Among these

programs, the PPP authorized $349,000,000,000 in forgivable loans to small businesses to retain

workers and maintain payroll, make mortgage interest payments, lease payments, and utility

payments.

14. The PPP Borrower Application Form required the borrower to submit

documentation that established the borrower’s eligibility for the loan and to make a series of

certifications in order to be approved for the PPP loan by a financial institution. Acceptable

documentation to establish eligibility for the PPP loan included payroll processor records, payroll

tax filings, Forms 1099-MISC, bank records, or income and expense forms from a sole

proprietorship.

15. PPP loans were required to be re-paid over two-years at an interest rate of 1%. The

maximum loan amount was $10,000,000 per business. PPP loans were forgivable for the sum of

documented payroll costs, covered mortgage interest payments, covered lease payments, and

covered utilities. Originally, not more than 25% of the forgiven amount could have been spent for

eligible non-payroll costs. Later, not more than 40% of the forgiven amount could have been spent

for eligible non-payroll costs.

U.S. Bank National Association

16. U.S. Bank National Association (US Bank) was a financial institution

headquartered in Cincinnati, Ohio, that did business in Jefferson City, Missouri. The deposits of

Case 2:22-cr-04051-RK Document 1 Filed 09/14/22 Page 8 of 26
US Bank were insured by the Federal Deposit Insurance Corporation (FDIC), under certificate

number 6548. U.S. Bank maintained a banking relationship with business entities controlled by

KEILHOLZ. After March 27, 2020, US Bank participated in the SBA’s PPP. US Bank made

three PPP loans to entities solely owned by KEILHOLZ.

17. On April 16, 2020, KEILHOLZ applied to US Bank for a PPP loan to TRK

Construction. In his application KEILHOLZ identified himself as the sole owner, falsely stated

the business had 14 employees and an average monthly payroll of $1,434,424, and falsely certified

that the purpose of the loan was to fund payroll, lease and mortgage interest, utilities, and

salary/commission. In supporting documentation, KEILHOLZ falsely claimed that TRK

Construction had $18,875,308.00 in gross receipts or sales for 2019. On May 8, 2020,

KEILHOLZ signed the SBA Application and Note for a $1,706,260.00 PPP loan for TRK

Construction. On May 11, 2020, the PPP loan proceeds were deposited into TRK Construction’s

US Bank account ending in 7961.

18. On May 28, 2020, KEILHOLZ applied to US Bank for a $7,818,705 PPP loan to

TRK Valpo based upon a claimed average monthly payroll of $3,127,482. In IRS Schedule C

Forms submitted with the application, KEILHOLZ falsely claimed that TRK VALPO had

$39,469,429.00 in gross receipts or sales for 2019. KEILHOLZ submitted materially different

and false IRS Forms 941, IRS Schedule C’s, and MDES and IDWD quarterly payroll wage reports

in his application. On May 28, 2020, in supporting documentation, KEILHOLZ falsely claimed

TRK Valpo employed 12 persons during the first quarter of 2019. On June 11, 2020, in revised

documentation, KEILHOLZ falsely claimed TRK Valpo employed 170 persons during the first

Case 2:22-cr-04051-RK Document 1 Filed 09/14/22 Page 9 of 26
quarter of 2019. On June 18, 2020, US Bank denied this application because it was unable to

verify the required payroll information form TRK Valpo.

19. On June 22, 2020, KEILHOLZ applied to US Bank for a PPP loan to TL Builders.

In his application KEILHOLZ identified himself as the sole owner, falsely stated the business

had 180 employees and an average monthly payroll of $1,447,526, and falsely certified the purpose

of the loan was to fund payroll, lease and mortgage interest, and utilities. In supporting

documentation, KEILHOLZ submitted false IRS Forms 940 and 941 that did not identify

employees by name or social security number. On June 30, 2020, KEILHOLZ signed the SBA

Application and Note for a $3,618,815.00 PPP loan for TL Builders. On July 2, 2020, the PPP

loan proceeds were deposited in TL Builders’ US Bank account ending in 2279. In connection

with this loan, KEILHOLZ submitted a Schedule C for TL Builders that falsely reported gross

receipts or sales for 2019 in the amount of $27,082,030.00.

20. On June 1, 2020, KEILHOLZ applied to US Bank for a PPP loan to Project

Design. In his application, KEILHOLZ identified himself as sole owner, falsely stated the

business had 18 employees and an average monthly payroll of $1,561,543, and certified the

purpose of the loan was to fund payroll, lease and mortgage interest, and utilities. In supporting

documentation KEILHOLZ falsely claimed that Project Design had $34,654,789.00 in gross

receipts or sales for 2019. KEILHOLZ provided US Bank with a MDES Quarterly Contribution

and Wage Report for the first quarter of 2020 that falsely purported that Project Design paid 215

employees aggregate wages of $4,785,169.00. The social security numbers KEILHOLZ

associated to 196 of those purported employees did not match the names of the actual persons

assigned to those social security accounts. On July 20, 2020, KEILHOLZ signed the SBA

Case 2:22-cr-04051-RK Document 1 Filed 09/14/22 Page 10 of 26
Application and Note for a $3,903,857.00 PPP loan for Project Design and the PPP loan proceeds

were deposited into Project Design’s US Bank account ending in 2290.

The Central Trust Bank

21. The Central Trust Bank (Central Bank) was a financial institution headquartered in

Jefferson City, Missouri. The deposits of Central Bank were insured by the Federal Deposit

Insurance Corporation (FDIC), under certificate number 12633. After March 27, 2020, Central

Bank participated in the SBA’s PPP. Central Bank made one PPP loan to an entity solely owned

by KEILHOLZ.

22. On June 17, 2020, KEILHOLZ applied to Central Bank for a PPP loan to TRK

Valpo. In his SBA Borrower Application Form, KEILHOLZ identified himself as the sole owner,

falsely stated the business had 170 employees and an average monthly payroll of $1,280,806, and

falsely certified the purpose of the loan was to fund payroll, lease and mortgage interest, and

utilities. In supporting documentation, KEILHOLZ falsely claimed that TRK Valpo had

$34,200,282.00 in gross receipts or sales for 2019. In supporting documentation, KEILHOLZ

included MDES and IDWD wage reports for all of 2019 which falsely claimed that TRK Valpo

paid aggregate wages of $15,286,667.00 to approximately 189 purported employees. The social

security numbers KEILHOLZ associated to 160 of those purported employees did not match the

names of the actual persons assigned to those social security accounts. On June 23, 2020,

KEILHOLZ signed a Promissory Note for a $3,202,000.00 PPP loan for TRK Valpo and the loan

proceeds were deposited into TRK Valpo’s Central Bank account ending in 5804.

Case 2:22-cr-04051-RK Document 1 Filed 09/14/22 Page 11 of 26
Facts Common to PPP Loans Made to
TRK Construction, TL Builders, Project Design, and TRK Valpo

23. In connection with each of the PPP loans made to TRK Construction, TL Builders,

Project Design, and TRK Valpo, in the aggregate amount of $12,430,932.00, KEILHOLZ had to

answer the following question: “Is the Applicant or any owner of the Applicant an owner of any

other business, or have common management with any other business? If yes, list all such

businesses and describe the relationship on a separate sheet identified as addendum A.”

KEILHOLZ did not identify his common 100% ownership of TRK Construction, TL Builders,

Project Design, and TRK Valpo in any completed PPP loan application.

24. In connection with the PPP loans made to TRK Construction, TL Builders, Project

Design, and TRK Valpo, KEILHOLZ falsely certified the following:

a. that TRK Construction, TL Builders, Project Design, and TRK Valpo were

in operation on February 15, 2020, and had employees to whom salaries were then;

b. that TRK Construction, TL Builders, Project Design, and TRK Valpo were

eligible to receive a PPP loan under the SBA rules in effect at the time of the application;

c. that TRK Construction, TL Builders, Project Design, and TRK Valpo would

only use PPP loan proceeds for business-related purposes specified in the loan application

and consistent with SBA rules;

d. that the purpose for the PPP loans to TRK Construction, TL Builders,

Project Design, and TRK Valpo included payroll, lease and mortgage interest, and utilities;

and,

e. the information provided in the PPP loan application, and supporting

documentation was true and accurate in all material respects.

Case 2:22-cr-04051-RK Document 1 Filed 09/14/22 Page 12 of 26
COUNTS 1 through 8
(Bank Fraud)
18 U.S.C. § 1344(1)

Scheme and Artifice to Defraud

25. The factual allegations in paragraphs 1 through 24, inclusive, of this Indictment are

incorporated by reference as if fully set forth to allege a scheme and artifice to defraud.

26. The purpose of the scheme and artifice to defraud Hawthorn Bank, US Bank, and

Central Bank was for the defendant to obtain loans, loan extensions, loan renewals, and loan

forbearance on conventional loans by providing materially false information to Hawthorn Bank

and to obtain PPP loans by providing materially false eligibility information to US Bank and

Central Bank.

27. It was further part of the scheme and artifice in connection with extensions,

renewals, and forbearance on conventional loans at Hawthorn bank that KEILHOLZ provided

Hawthorn Bank with an insufficient funds check in the amount of $22,749.28 on or about

December 31, 2019, for payment of interest on Hawthorn Bank loans 101010203, 101011285, and

101011737.

28. It was further part of the scheme and artifice in connection with the US Bank PPP

loan to TRK Construction that KEILHOLZ provided US Bank with the following materially false

forms: an IRS Form 941 for the fourth quarter of 2019, IDWD Quarterly Payroll Reports for the

second, third, and fourth quarters of 2019, and MDES Quarterly Contribution and Wage Reports

for the second, third, and fourth quarters of 2019.

Case 2:22-cr-04051-RK Document 1 Filed 09/14/22 Page 13 of 26
29. It was further part of the scheme and artifice in connection with the US Bank PPP

loan to TL Builders that KEILHOLZ provided US Bank with the following materially false

forms: an IRS Form 940 for 2019, IRS Forms 941 for all four quarters of 2019.

30. It was further part of the scheme and artifice in connection with the US Bank PPP

loan to Project Design that KEILHOLZ provided US Bank with the following materially false

forms: IRS Forms 941 for all four quarters of 2019, and the first quarter of 2020, and a MDES

Quarterly Contribution and Wage Report for the first quarter of 2020.

31. It was further part of the scheme and artifice in connection with the US Bank PPP

loan application of TRK Valpo that KEILHOLZ provided US Bank with the following materially

false forms: IRS Forms 941 for all four quarters of 2019, IRS Schedule C Forms, MDES Quarterly

Contribution and Wage Reports for all four quarters of 2019, and IDWD for all four quarters of

2019.

32. It was further part of the scheme and artifice in connection with the Central Bank

PPP loan to TRK Valpo that KEILHOLZ provided Central Bank with the following materially

false forms: an IRS Form 940 for 2019, MDES Quarterly Contribution and Wage Reports for all

four quarters of 2019, and IDWD Quarterly Payroll Reports for all four quarters of 2019.

33. It was further part of the scheme and artifice that KEILHOLZ falsely attested that

the information in the PPP loan applications for TRK Construction, TL Builders, Project Design,

and TRK Valpo were true and accurate.

34. It was further part of the scheme and artifice in connection with the expenditure of

PPP loan proceeds that KEILHOLZ used PPP loan proceeds for unauthorized purposes other than

legitimate payroll, lease and mortgage interest, and utilities as required by the PPP.

Case 2:22-cr-04051-RK Document 1 Filed 09/14/22 Page 14 of 26
Execution of the Scheme and Artifice to Defraud

35. On or about the dates set forth in each individual count, within Cole County and

elsewhere within the Western District of Missouri, and elsewhere, the defendant, TOD RAY

KEILHOLZ, a/k/a “Todd Ray Keilholz,” executed and attempted to execute the above-described

scheme and artifice to defraud, as follows:

COUNT DATE ACT OR ATTEMPTED ACT OF EXECUTION
1 12/31/2019 Passed check number 5191, in the amount $22,749.28, and drawn upon
TRK Construction’s US Bank account ending in 7961 at Hawthorn
Bank when KEILHOLZ knew there were insufficient funds to pay that
check at the time it was written and the time it was passed.
2 4/16/2020 Provided US Bank with IDWD and MDES quarterly wage reports for
the fourth quarter of 2019 for TRK Construction to prove its eligibility
for a PPP loan, when TRK Construction did not file these reports with
the States of Indiana and Missouri and paid only $27,469.09 in wages.
3 6/11/2020 Provided US Bank with MDES Quarterly Contribution and Wage
Reports for all quarters of 2019 for TRK Valpo to prove its eligibility
for a PPP loan, when TRK Valpo did not file these reports with the State
of Missouri and paid no wages.
4 6/17/2020 Provided Central Bank with MDES Quarterly Contribution and Wage
Reports for all quarters of 2019 for TRK Valpo to prove its eligibility
for a PPP loan, when TRK Valpo did not file these reports with the State
of Missouri and paid no wages.
5 6/25/2020 Provided US Bank with IRS Forms 941 for all quarters of 2019 as an
attachment to prove the eligibility of TL Builders for a PPP loan from
US Bank, when TL Builders did not file these reports with the Internal
Revenue Service and paid no wages.
6 7/14/2020 Provided US Bank with a MDES Quarterly Contribution and Wage
Report for the first quarter of 2020 for Project Design to prove its
eligibility for a PPP loan from US Bank, when Project Design did not
file this report with the State of Missouri and paid no wages.
7 5/20/2021 Submitted an SBA Form 3508EZ (01/21) to US Bank that falsely
represented that the entire amount of the $3,618,815 PPP loan to TL
Builders was spent on payroll expenses to cause US Bank to certify to
the SBA that the entire $3,618,815 PPP loan should be forgiven.
8 9/23/2021 Submitted an SBA Form 3508 (07/21) to US Bank that falsely
represented that the entire amount of the $1,706,260 PPP loan to TRK
Construction was spent on payroll expenses to cause US Bank to certify
to the SBA that the entire $1,706,260 PPP loan should be forgiven.

Case 2:22-cr-04051-RK Document 1 Filed 09/14/22 Page 15 of 26
36. All in violation of Title 18, United States Code, Section 1344(1).

COUNTS 9 through 14
(False Statements to a Financial Institution)
18 U.S.C. § 1014

37. On or about the dates set forth below in each individual count, in Cole County and

elsewhere in the Western District of Missouri, and elsewhere, the defendant, TOD RAY

KEILHOLZ, a/k/a “Todd Ray Keilholz,” knowingly made and caused to be made the false report

and statement of fact identified in each individual count for the purpose of influencing the actions

of the FDIC insured financial institution identified in each individual count:

COUNT DATE MATERIALLY FALSE REPORT AND STATEMENT OF FACT
9 9/21/2018 A purported 2017 IRS Form 1040 Tax Return for KEILHOLZ which
stated on line 12 business income of $6,255,433 and was never filed with
the IRS.
10 2/12/2020 E-mail sent from KEILHOLZ to a loan officer at Hawthorn Bank at
approximately 9:56 a.m.
11 5/8/2020 US Bank SBA Payroll Protection Plan Promissory Note (Form
PLNTEUSBR01 04/2020) for TRK Construction.
12 6/23/2020 Central Bank Borrower Certification for TRK Valpo.
13 6/30/2020 US Bank SBA Payroll Protection Plan Promissory Note (Form
PLNTEUSBR01 04/2020) for TL Builders.
14 7/20/2020 US Bank SBA Payroll Protection Plan Promissory Note (Form
PLNTEUSBR01 06/2020) for Project Design.

38. All in violation of Title 18, United States Code, Sections 1014 and 2.

COUNTS 15 through 18
(False Statements to the Small Business Administration)
18 U.S.C. § 1001

39. On or about the dates set forth below in each individual count, in Cole County and

elsewhere within the Western District of Missouri, and elsewhere, the defendant, TOD RAY

KEILHOLZ, a/k/a “Todd Ray Keilholz,” in a matter within the jurisdiction of the SBA, an agency

of the United States, did knowingly and willfully make and use the materially false writing and

document identified in each individual count:
16

Case 2:22-cr-04051-RK Document 1 Filed 09/14/22 Page 16 of 26
COUNT DATE MATERIALLY FALSE WRITING AND DOCUMEWNT
15 5/8/2020 Paycheck Protection Program SBA Borrower Application Form for TRK
Construction.
16 6/17/2020 Paycheck Protection Program SBA Borrower Application Form for TRK
Valpo.
17 6/30/2020 Paycheck Protection Program SBA Borrower Application Form for TL
Builders.
18 7/20/2020 Paycheck Protection Program SBA Borrower Application Form for
Project Design.

40. All in violation of Title 18, United States Code, Section 1001.

COUNTS 19 through 28
(Aggravated Identity Theft)
18 U.S.C. § 1028A(a)(1)

41. On or about the dates set forth below, in Cole County and elsewhere within the

Western District of Missouri, and elsewhere, in each individual count, the defendant, TOD RAY

KEILHOLZ, a/k/a “Todd Ray Keilholz,” knowingly used, without lawful authority, the means of

identification of another person, during and in relation to the commission of a felony enumerated

in 18 U.S.C. § 1028A(c)(1), that is, Bank Fraud, knowing that the means of identification belonged

to another actual person:

Count Date Means of Identification Enumerated Felony Charged
19 6/11/2020 Name and Social Security number Bank Fraud as charged in Count 3
of M.S.P.
20 6/17/2020 Name and Social Security number Bank Fraud as charged in Count 4
of M.S.P.
21 6/11/2020 Social Security number of D.N. Bank Fraud as charged in Count 3
22 6/17/2020 Social Security number of D.N. Bank Fraud as charged in Count 4
23 6/11/2020 Social Security number of L.M.H. Bank Fraud as charged in Count 3
24 6/17/2020 Social Security number of L.M.H. Bank Fraud as charged in Count 4
25 6/11/2020 Social Security number of J.R.W. Bank Fraud as charged in Count 3
26 6/17/2020 Social Security number of J.R.W. Bank Fraud as charged in Count 4
27 6/11/2020 Name and Social Security number Bank Fraud as charged in Count 3
of T.R.M.
28 6/17/2020 Name and Social Security number Bank Fraud as charged in Count 4
of T.R.M.

Case 2:22-cr-04051-RK Document 1 Filed 09/14/22 Page 17 of 26
42. All in violation of Title 18, United States Code, Section 1028A(a)(1).

COUNTS 29 through 52
(Engaging in Monetary Transactions in Property Derived from Specified Unlawful Activity)
18 U.S.C. § 1957(a)

43. On or about the dates set forth below in each individual count, in Cole County and

elsewhere within the Western District of Missouri, and elsewhere, the defendant, TOD RAY

KEILHOLZ, a/k/a “Todd Ray Keilholz,” knowingly engaged and attempted to engage in the

following monetary transactions by, through, or to a financial institution, affecting interstate or

foreign commerce, in criminally derived property of a value greater than $10,000, that is the

deposit and transfer of funds and monetary instruments, such property having been derived from

a specified unlawful activity, that is, bank fraud in violation of 18 U.S.C. § 1344(1):

COUNT DATE MONETARY TRANSACTION
29 5/11/2020 Wire transferred $700,000.00, funded by PPP loan proceeds, from TRK
Construction’s US Bank account ending in 7961, to Tauber Law
Office’s IOLTA for “Property Purchase/Refinance.”
30 5/11/2020 Wrote check number 8011, funded by PPP loan proceeds, drawn on
TRK Construction’s US Bank account ending in 7961, payable to his
wife in the amount of $200,000.00, for “loan repayment,” that was paid
on May 12, 2020.
31 5/11/2020 Wrote check number 8013, funded by PPP loan proceeds, drawn on
TRK Construction’s US Bank account ending in 7961, payable to
McAllister Leasing & Excavating, in the amount of $100,000.00, for
“Valpo Excavating” that was paid on May 12, 2020.
32 5/11/2020 Wrote check number 8012, funded by PPP loan proceeds, drawn on
TRK Construction’s US Bank account ending in 7961, payable to
Adams Masonry, in the amount of $100,000.00, for “Valpo Masonry”
that was paid on May 13, 2020.
33 6/24/2020 Wire transferred $1,500,000.00, funded by PPP loan proceeds, from
TRK Valpo’s Central Bank account ending in 5804, to Tauber Law
Office’s IOLTA, for “Payroll/Rent.”
34 6/26/2020 Wire transferred $54,143.23, funded by PPP loan proceeds, from TRK
Valpo’s Central Bank account ending in 5804, to ACS Asset Compliant
Solutions to payoff a Kubota Compact Track Loader SVL75-2HFWC,
serial number 36862, equipped with a Land Pride AP-PFL5560, serial
number 1058098K, and a Kubota Ap-HD74LLC.

Case 2:22-cr-04051-RK Document 1 Filed 09/14/22 Page 18 of 26
COUNT DATE MONETARY TRANSACTION
35 7/3/2020 Withdrew $3,302,830.61 in cash, funded by PPP loan proceeds, from
TL Builder’s US Bank account ending in 2279, purchased a
$3,302,830.61 cashier’s check, payable to TRK Construction, and
deposited that cashier’s check into TRK Construction’s Hawthorn Bank
account ending in 1523 to payoff outstanding conventional loans of
TRK Construction and TRK Valpo at Hawthorn Bank.
36 7/20/2020 Wrote check number 5080, funded by PPP loan proceeds, drawn on
Project Design’s US Bank account ending in 2290, payable to his wife
in the amount of $50,000.00, for “loan repayment,” that was paid on
July 20, 2020.
37 7/20/2020 Wrote check number 5081, funded by PPP loan proceeds, drawn on
Project Design’s US Bank account ending in 2290, payable to C.K., his
ex-wife, in the amount of $75,000.00, for “loan repayment,” that was
paid on July 20, 2020.
38 7/22/2020 Wire transferred $1,000,000.00, funded by PPP loan proceeds, from
Project Design’s US Bank account ending in 2290, to Tauber Law
Office’s IOLTA, for “Purchase Goods/Services.”
39 8/4/2020 Wrote check number 8040, funded by PPP loan proceeds, drawn on
TRK Construction’s US Bank account ending in 7961, payable to Pulse
Design Group, Inc. in the amount of $333,258.00 for “VALPO
Expenses, Architect,” that was paid on August 5, 2020.
40 8/10/2020 Wrote check number 5005, funded by PPP loan proceeds, drawn on
TRK Valpo’s US Bank account ending in 8843, payable to C.K., his ex-
wife, in the amount of $25,000.00, for “PR,” that was paid on August
10, 2020.
41 8/11/2020 Wrote check number 7010, funded by PPP loan proceeds, drawn on
Project Design’s US Bank account ending in 2290, payable to BMW
Financial Services in the amount of $46,355.01, to pay-off a loan on a
2019 BMW X5 xDrive 40i, VIN 5UXCR6C53KLK87363 titled to TRK
Construction.
42 8/18/2020 Withdrew $18,262.00 in cash, funded by PPP loan proceeds, from TL
Builders’ US Bank account ending in 2279, and purchased a cashier’s
check in that amount payable to Jim Butler Chevrolet for the purchase
of a 2020 Chevrolet Silverado 3500HD, VIN 1GC4YVEY6LF284743,
titled to Project Design.
43 8/24/2020 Wrote check number 5006, funded by PPP loan proceeds, drawn on
TRK Valpo’s US Bank account ending in 8843, payable to C.K., his ex-
wife, in the amount of $25,000.00, that was paid on August 24, 2020.
44 9/14/2020 Wrote check number 5008, funded by PPP loan proceeds, drawn on
TRK Valpo’s US Bank account ending in 8843, payable to his wife in
the amount of $25,000.00, for “loan repayment,” that was paid on
September 14, 2020.

Case 2:22-cr-04051-RK Document 1 Filed 09/14/22 Page 19 of 26
COUNT DATE MONETARY TRANSACTION
45 9/25/2020 Wrote check number 5194, funded by PPP loan proceeds, drawn on
TRK Construction’s US Bank account ending in 7961, payable to
Heritage Tractor, in the amount of $12,623.05, for the purchase of a
2020 John Deere Z950R ZTrak, PIN 1TC950RCKLT080362, that was
paid on September 29, 2020.
46 10/7/2020 Wrote check number 7020, funded by PPP loan proceeds, drawn on
Project Design’s US Bank account ending in 2290, payable to C.K., his
ex-wife, in the amount of $25,000.00, for “loan repayment,” that was
paid on October 15, 2020.
47 10/9/2020 Withdrew $49,326.53 in cash, funded by PPP loan proceeds, from TL
Builders’ US Bank account ending in 2279, and purchased a cashier’s
check in that amount payable to Cole County Abstract & Title Co. for
the purchase of real properties located at 405 Pheasant Run, Jefferson
City, Missouri, and 6505 Parkview Avenue, Jefferson City, Missouri.
48 10/15/2020 Wrote check number 7022, funded by PPP loan proceeds, drawn on
Project Design’s US Bank account ending in 2290, payable to his wife
in the amount of $25,000.00, for “loan repayment,” that was paid on
October 15, 2020.
49 11/2/2020 Withdrew $73,000.00 in cash, and $543.00 in cash, funded by PPP loan
proceeds, from TRK Construction’s US Bank account ending in 7961,
and purchased a $73,543.00 cashier’s check payable to Jim Butler
Chevrolet for the purchase of a 2021 Chevrolet Tahoe, VIN
1GNSKTLK4MR108934, titled to A.O.B.
50 11/18/2020 Withdrew $22,401.00 in cash, funded by PPP loan proceeds, from
Project Design’s US Bank account ending in 2290, and purchased a
cashier’s check in that amount payable to Jim Butler Chevrolet for the
purchase a 2021 Chevrolet Silverado 3500, VIN
1GC4YUEY9MF114677 and a 2021 Chevrolet Silverado 1500, VIN
1GCRYAEF4MZ115821, both titled to TL Builders.
51 12/3/2020 Wrote check number 7028, funded by PPP loan proceeds, drawn on
Project Design’s US Bank account ending in 2290, payable to his wife
in the amount of $25,000.00, for “loan repayment,” that was paid on
December 3, 2020.
52 1/7/2021 Wrote check number 7030, funded by PPP loan proceeds, drawn on
Project Design’s US Bank account ending in 2290 payable to himself in
the amount of $170,000.00, for “Settlement/Property Bought,”
withdrew $10,000 in cash from Project Design’s US Bank account
ending in 2290, purchased a $170,000 cashier’s check and a $5,000
cashier’s check, both payable to his attorney to settle a lawsuit filed by
the Kansas City Chiefs Football Club.

44. All in violation of Title 18, United States Code, Section 1957(a).

Case 2:22-cr-04051-RK Document 1 Filed 09/14/22 Page 20 of 26
FORFEITURE ALLEGATION

45. The factual allegations of this Indictment are re-alleged and incorporated as though

fully set forth herein for the purpose of alleging forfeiture to the United States pursuant to the

provisions of Title 18, United States Code, Sections 981(a)(1)(A) and (C) and 982(a)(1) and

(2)(A), and Title 28, United States Code, Section 2461.

46. As a result of the offenses alleged in this Indictment in Counts 1 through 52,

inclusive, and pursuant to Title 18, United States Code, Sections 981(a)(1)(A) and (C) and

982(a)(1) and (2)(A) and Title 28, United States Code, Section 2461, the defendant, TOD RAY

KEILHOLZ, a/k/a “Todd Ray Keilholz,” as to the Indictment, shall forfeit to the United States

all property, real and personal, constituting, involved in, and derived from any proceeds the

defendant obtained directly and indirectly as a result of the violations incorporated by reference in

this Forfeiture Allegation. Including but not limited to the following:

Real Property

47. The real property known and numbered as 508 Summerhill Drive, Jefferson City,

Missouri, with all its appurtenances, improvements, and attachments thereon, and is more fully

described as:

LOT NO. 60, PARKVIEW MEADOWS, SECTION 2, PER PLAT OF RECORD
IN PLAT BOOK 12, PAGE 278, COLE COUNTY RECORDER'S OFFICE; SAID
PARKVIEW MEADOWS, SECTION 2, BEING A SUBDIVISION OF PART OF
THE NORTHEAST QUARTER OF SECTION 2, TOWNSHIP 44 NORTH,
RANGE 13 WEST, AND PART OF THE SOUTH HALF OF THE SOUTHEAST
QUARTER OF SECTION 35, TOWNSHIP 45 NORTH, RANGE 13 WEST.

48. The real property known and numbered as 405 Pheasant Run, Jefferson City,

Missouri, with all its appurtenances, improvements, and attachments thereon, and is more fully

described as:

Case 2:22-cr-04051-RK Document 1 Filed 09/14/22 Page 21 of 26
LOT NO 54, PARKVIEW MEADOWS SECTION 2, PER PLAT OF RECORD
IN PLAT BOOK 12, PAGE 278, COLE COUNTY RECORDER’S OFFICE; SAID
PARKVIEW MEADOWS SECTION 2, BEING A SUBDIVISION OF PART OF
THE NORTHEAST QUARTER OF SECTION 2, TOWNSHIP 44 NORTH,
RANGE 13 WEST, AND PART OF THE SOUTH HALF OF THE SOUTHEAST
QUARTER OF SECTION 35, TOWNSHIP 45 NORTH, RANGE 13 WEST.

49. The real property known and numbered as 6506 Parkview Avenue, Jefferson City,

Missouri, with all its appurtenances, improvements, and attachments thereon, and is more fully

described as:

LOT NO. 17, PARKVIEW MEADOWS SECTION 1, PER PLAT OF RECORD
IN PLAT BOOK 12, PAGE 227, COLE COUNTY RECORDER’S OFFICE; SAID
PARKVIEW MEADOWS SECTION 1, BEING A SUBDIVISION OF PART OF
THE NORTH HALF OF SECTION 2, TOWNSHIP 44 NORTH, RANGE 13
WEST, AND PART OF THE SOUTHWEST QUARTER OF THE SOUTHEAST
QUARTER OF SECTION 35, TOWNSHIP 45 NORTH, RANGE 13 WEST.

50. The real property known and numbered as 1425 Glendale Boulevard, Valparaiso,

Indiana, with all its appurtenances, improvements, and attachments thereon, and is more fully

described as:

LOT 4 IN PORTER MEDICAL ADDITION, IN THE CITY OF VALPARAISO,
AS PER PLAT THEREOF, RECORDED IN PLAT FILE 20-B-1, IN THE
OFFICE OF THE RECORDER OF PORTER COUNTY, INDIANA.

51. The real property known and numbered as 3311 Shamrock Drive, Jefferson City,

Missouri, with all its appurtenances, improvements, and attachments thereon, and is more fully

described as:

LOT NO. 1, SHAMROCK HILLS, PER PLAT OF RECORD IN PLAT BOOK 11,
PAGE 691, COLE COUNTY RECORDER'S OFFICE; SAID SHAMROCK
HILLS, BEING A SUBDIVISION OF PART OF THE NORTHWEST QUARTER
OF SECTION 25, AND PART OF THE NORTHEAST QUARTER OF SECTION
26, ALL IN TOWNSHIP 44 NORTH, RANGE 11 WEST.

Case 2:22-cr-04051-RK Document 1 Filed 09/14/22 Page 22 of 26
52. The real property known and numbered as 3319 Shamrock Drive, Jefferson City,

Missouri, with all its appurtenances, improvements, and attachments thereon, and is more fully

described as:

LOT NO. 2, SHAMROCK HILLS, PER PLAT OF RECORD IN PLAT BOOK 11,
PAGE 691, COLE COUNTY RECORDER'S OFFICE; SAID SHAMROCK
HILLS, BEING A SUBDIVISION OF PART OF THE NORTHWEST QUARTER
OF SECTION 25, AND PART OF THE NORTHEAST QUARTER OF SECTION
26, ALL IN TOWNSHIP 44 NORTH, RANGE 11 WEST.

53. The real property known and numbered as 3539 Monroe Street, La Porte, Indiana,

Parcel number: 461105301007000058, with all its appurtenances, improvements, and attachments

thereon, and is more fully described as:

A parcel of land in the Southwest Quarter of Section 5, Township 36 North, Range
2 West of the Second Principal Meridian, located in the City of LaPorte, Indiana,
said parcel more particularly described as follows: Commencing at the Northwest
corner of the Southwest Quarter of said Section 5; thence South 00° 00' 00" West,
along the West line of said Southwest Quarter, 545.68 feet to the centerline of
Indiana State Road Number 4; thence South 67° 07’ 00" East, along said centerline,
426.03 feet; thence North 00° 00' 14" East, 38.00 feet to the North Right-of- Way
line of said State Road Number 4, said point being the Point of Beginning; thence
continuing North 00° 00' 14" East, 372.12 feet; thence South 89° 59' 46" East,
105.68 feet; thence South 71° 42' 03" East, 496.05 feet to the West line of a parcel
of land conveyed to Alford L. & Norma J. Hughes by Document Number 2014R-
11332 in the Office of the Recorder of La Porte County, Indiana; thence South 18°
01' 34" West, along said West line, 425.10 feet to the North line of the 70 foot
Right-of-Way of Indiana State Road Number 4; thence North 67° 07' 00" West,
along said Right-of-Way, 483.15 feet to the Point of Beginning, containing 5.00
acres, more or less.

Personal Property

54. A 2020 Chevrolet Silverado 3500HD, VIN 1GC4YVEY6LF284743, titled to

Project Design.

55. A 2021 Chevrolet Tahoe, VIN 1GNSKTKL4MR108934, titled to A.O.B.

Case 2:22-cr-04051-RK Document 1 Filed 09/14/22 Page 23 of 26
56. A 2021 Chevrolet Silverado 3500, VIN 1GC4YUEY9MF114677 titled to TL

Builders.

57. A 2021 Chevrolet Silverado 1500, VIN 1GCRYAEF4MZ115821 titled to TL

Builders.

58. A 2019 BMW X5 xDrive 40i, VIN 5UXCR6C53KLK87363 titled to TRK

Construction.

59. A 2020 John Deere Z950R ZTrak, PIN 1TC950RCKLT080362 purchased by

KEILHOLZ.

60. A 2020 John Deere Select Series X390 Tractor 48 Accel Deep (48A) Mower Deck,

PIN 1MOX390ATLM091818, purchased by KEILHOLZ.

61. A Kubota Compact Track Loader SVL75-2HFWC, serial number 36862, equipped

with a Land Pride AP-PFL5560, serial number 1058098K, and a Kubota Ap-HD74LLC purchased

by TRK Construction.

Money Judgement

62. A money judgment representing proceeds obtained by the defendant, in that, the

sum in aggregate constitutes and derived from proceeds traceable to the offenses set forth in the

Indictment and all property involved in and derived from proceeds from the money laundering

offenses.

Substitute Assets

63. 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;

Case 2:22-cr-04051-RK Document 1 Filed 09/14/22 Page 24 of 26
b. has been transferred, 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;

it is the intention 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), to seek forfeiture of any other

property of the defendant up to the value of forfeitable property, including but not limited to the

following:

64. a 2017 Ford F250 Lariat, VIN# 1FT7W2BT9HEC54224 titled to TRK

Construction;

65. a 2019 Doolittle Utility Trailer; VIN# 1DGRSA1215KM033719 titled to

KEILHOLZ and TRK Construction;

66. a 2012 Doolittle Utility Trailer; VIN# 1DGRS0810CM098206 titled to Lisa

Keilholz;

67. a 2013 Cargo Trailer; 20 foot enclosed; VIN# 56JTE202XDA131723 titled to TRK

Construction; and,

68. a 2012 Cargo Trailer; 16 foot enclosed; VIN# 16HCB1014CH194017 titled to TRK

Construction.

A TRUE BILL.

Casey Castrop
FOREPERSON OF THE GRAND JURY

Case 2:22-cr-04051-RK Document 1 Filed 09/14/22 Page 25 of 26
Michael S. Oliver
Michael S. Oliver
Assistant United States Attorney
Missouri Bar No. 41832

Dated: September 13th, 2022

Case 2:22-cr-04051-RK Document 1 Filed 09/14/22 Page 26 of 26

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