Indictment — United States v. Olamide Olatayo Bello, Eastern District of Texas (Document 24)

Summary

A sealed grand jury indictment filed June 15, 2023 as Document 24 in Case 4:23-cr-00136-ALM-BD in the U.S. District Court for the Eastern District of Texas, Sherman Division, naming Olamide Olatayo Bello of McKinney, Texas, and other defendants. Count 1 charges conspiracy to commit wire fraud under 18U.S.C. § 1349 from in or around April 2020, alleging that Bello recruited co-conspirators to use existing or newly created businesses to apply for PPP and EIDL loans, helped fabricate supporting documents and submitted applications online, often from an IP address at Bello's residence. It alleges the defendants spent the funds on cash withdrawals, luxury vehicles, home improvements and international wires, and paid part to Bello. As one example, it states Amur Equipment Finance funded first and second draw PPP loans of $111,332 each to Preferred Oil & Gas Services, LLC in 2021.

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. Olamide Olatayo Bello, Eastern District of Texas (Document 24).” Original at archive.org. Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/indictment-no-4-23-cr-00136-dkt-24-e-d-tex-46ef957927/, SHA-256 c4f9dd02cdd56dca6f9fc3a8a4280673d5ce2d0fbc1130767234487562eede70.

Full text

Case 4:23-cr-00136-ALM-BD Document 24 Filed 06/15/23 Page 1 of 22 PageID #:
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IN THE UNITED STATES DISTRICT COURT
FOR THE EASTERN DISTRICT OF TEXAS
SHERMAN DIVISION

SEALED

Case No. 4:23CRl3( ?
Jud?e

INDICTMENT

THE UNITED STATES GRAND JURY CHARGES:

General Allegations

At all times material to the f cts set forth i this I dictment:

The Defe dants and related entities

1. Defendant Olamide Olatayo Bello ( Bello ) was an individu l residing in

McKinney, Texas, in the Easte District of Texas. Bello controlled nd mana ed the

following business organizations, which were located and operated in McKiimey, Texas,

in the Easte District of Texas:

a. Ajide Teclmology Corporation

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b. Smooth Multi-Services Platform

c. Obello Solutions Corporation

d. Obello, Inc.

e. Yembell

f. DOBIT

2. Defendant was an individual

residing in Carlsbad, New Mexico. Preferred Oil & Gas Services, LLC ( Preferred ) was

a business that was organized and operated in Midland, Texas, was the

managing member of Preferred.

3. Defendant w s an individual

residing in Midland, Texas. Dfash Transportation, LLC ( Dfash ) was a business that

was organized and ope ated in Midland, Texas. was the organizer and

registered agent of Dfash.

4. was an individual residing in

Midland, Texas. Kenny Sunn ( Kenny ) was a business organization located and

operated in Midland, Texas. was the registe ed agent of Kenny.

5. Defendant was an individual

residing in Spring, Texas. B-Light Services (“B-Light”) was a business that was

organized and operated in Frisco, Texas, in the Eastern District of Texas, m

was a manager and the registered agent of B-Light.

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in Odessa, Tex s. Victor Motor s, LLC ( Victor ) was business that was organized and

operated in Odessa, Te as. wag managing member and registered agent of

Victor.

7. Defendant was an individual residing

in Dallas, Texas. Zuby Automobile (“Zuby ) was a business that was organized and

Defendant was an

residing in McKinney, Texas, in the Eastern District of Texas. Ejico Transportation,

LLC (“Ejico ), also known as Ejico, LLC, was a business that was organized and

operated in Garland, Texas. was the Chief Executive and registered agent of

Ejico.

9. Defendant was an individual residing

in Princeton, Texas, in the Easte n District of Texas. S-O-Y was a business that was

o ganized in Colorado. was affiliated with S-O-Y.

10. Defendant was an

individual residing in Katy, Texas. Yinxandpartners (“Yinx”) was a business that was

o ganized in Colorado and operated in Odessa, Texas. was the incorporator

and registered agent of Yinx.

Defendant was an

residing in Wylie, Texas, in the Eastern District of Texas. Josephine Catering Services

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was a business that was organized and operated in Dallas, Texas, was so|e

proprietor of Josephine Catering Services.

The Small Business Administration

12. The United States Small Business Administration ( SBA ) was an

executive-br nch agency of the United States government that ovided sup ort 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 ecovery of communities after disasters.

13. As part of this effort, the SBA enabled and p ovided for loans titrough

banks, credit unions, and other lenders. These loans have gove nment-backed

gua antees.

The Paycheck P otection Program

14. The Coronavirus Aid, Relief, and Economic Security ( CARES ) Act was

a federal law enacted in March 2020 and designed to provide emergency financial

assistance to the millions of Ame icans who were suffering the economic effects caused

by the COVID-19 pandemic. One source of relief provided by the CA ES Act was the

authorization of fo givable loans to small businesses for job retention and certain other

expenses, through a program referred to as the Paycheck Protection Program (“PPP”).

15. To obtain a PPP loan, a qualifying business was required to submit a PPP

loan application, which was signed by an autho ized representative of the business. The

PPP loan application requi ed the business (through its autho ized representative) to

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acknowledge the program rules and make certain affirmative certifications in order to be

eligible to obtain the PPP loan. In the PPP loan application (SBA Form 2483), the small

business (through its authorized representative) was equired to state, among other things,

its: (a) average monthly pa roll expenses, and (b) number of employees. These figures

were used to calculate the amount of money the small business was eligible to receive

under the PPP. In addition, businesses applying for a PPP loan were required to provide

documentation showing their payroll expenses.

16. A PPP loan application was processed by a participating lender. If a PPP

loan pplication was approved, the participating lender funde the PPP lo n using its own

monies, which were guaranteed by the SBA. Data from the application, including

information bout the borrower, the total amount of the lo n, and the listed number of

employees, was transmitted by the lender to the SBA in the course of processing the loan.

17. PPP loan proceeds were required to be used on certain permissible

expenses, including payroll costs, mortg ge interest, rent, and utilities. Under the

applicable PPP rules and guid nce, the interest and principal on the PPP loan is eligible

for forgiveness if the business spent the loan proceeds on these expense items within a

designated period of time and used a certain portion of the loan towards payroll

expenses.

The Economic Injury Disaster Loan Program

18. The Economic Injury Disaster Loan ( EIDL ) Program was an SBA

program that provided low-interest financing to small businesses, renters, and

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homeowners in regions affected by declared disasters. The CARES Act authorized the

SBA to provide EIDLs up to $2,000,000 to eligible small businesses experiencing

substantial financial dis uption due to the COVID-19 pandemic. In addition, the CA ES

Act authorized the SBA to issue advances of up to $10,000 to small businesses within

three da s of applying for an EIDE. The amount of the advance was determined by the

number of employees the applicant certified having. The advances did not have to be

repaid.

19. In order to obtain an EIDE and advance, a qualifying business was

required to submit an application to the SBA and provide information about its

operations, such as: (1) the number of employees, (2) gross revenues for the 12-month

period preceding the disaster, and (3) cost of goods sold in the 12-month period

preceding the disaster. The 12-month period for EIDLs for COVID-19 relief was from

January 31, 2019, to January 31, 2020. The applicant was also required to certify that all

the information in the application was true and correct to the best of the applicant s

knowledge.

20. EIDE applications were submitted directly to the SBA and processed by

the agency with support from a government contractor, Rapid Finance. The amount of

the loan, if the application were approved, was determined based on the information

provided by the applicant about employment, revenue, and cost of goods, as described

above. Any funds issued under an EIDE advance were issued directly by the SBA.

EIDE funds could be used for payroll expenses, sick leave, production costs, and

business obligations, such as debts, rent, and mortgage payments. If the applicant also

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obtained a loan under the PPP, the EIDL funds could not be used for the same purpose

as the PPP f nds.

COUNT 1

Violation: 18U.S.C. § 1349
(Conspiracy to Commit Wire Fraud)

21. From a proximately in or around April 2020, a d continuing through the

date of this Indictment, the exact dates being unknown to the G and Jury, in the Easte n

Distiict of Texas, and elsewhere, the defendants.

OLAMIDE OLATAYO BELLO

along with others, both known and unknown to the grand jury, did knowingly and

willfully conspire and agree to violate 18 U.S.C. § 1343, wire fraud, that is, to transmit

and cause to be transmitted by means of wire communication in interstate and foreign

commerce any writings, signs, signals, pictures, and sounds for the pur ose of executing

a scheme and a tifice to defr ud and for obtainin money and p operty by means of false

and fraudulent pretenses, representations, and promises.

Overview of the Conspiracy

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22. The defendants, led by Olamide Olatayo Bello ( Bello ), executed a

scheme to defraud lenders and the SBA. Bello recruited co-conspirators to use an

existing business and to create a business to submit applications to obtain PPP funding.

Once enlisted, Bello assisted his co-conspirators with the application paperwork,

including fabricating supporting documentation and submitting the application through

the online portals. On the applications, the defendants misrepresented material

information, such as the true nature of their business, the number of employees, and the

amount of payroll. Based on these material misrepresentations, the SBA, and other

financial institutions on behalf of the SBA, approved and issued loans to the defendants.

Once in receipt of the fraudulently obtained funds, the defendants did not use the money

as intended, such as to pay employee salaries, cover fixed debt and utility payments, and

continue health care benefits for employees. Instead, the defendants typically paid Bello,

transferred money to their personal accounts, and spent the funds on various personal

purchases.

Purpose of the Conspiracy

23. It was the general purpose of the conspiracy for the defendants and their co-

conspirators to unlawfully and unjustly enrich themselves by obtaining PPP and EIDL

loan proceeds through materially false and fraudulent pretenses, representations, and

promises.

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Manner and Means of the Conspiracy

24. The manner and means by which the defendants and their co-conspirato s

sought to accomplish the purpose of the conspiracy included, among others, the

following:

a. The defendants registered and used sham, non-operational businesses, and in
other instances existing businesses, under which they could submit PPP and
EIDL loan applications.

b. The defendants opened bank accounts under their names and their businesses
to receive, deposit, and transfer PPP and EIDL funds.

c. The defendants submitted materially false and fraudulent PPP and EIDL loan
applications, misrepresenting, among other things, the number of employees
and monthly payroll expenses.

d. The defendants submitted falsified and fabricated supporting documentation
in support of their loan applications.

e. The defendants submitted the applications and accessed their PPP and EIDL
loan accounts using the inte et, frequently from an internet protocol ( IP )
address that resolved back to Bello s residence in McKinney, Texas, in the
Eastern District of Texas.

f. The defendants used the PPP and EI L funds for unauthorized personal
purposes, including cash withdrawals, making luxury vehicle purchases, home
improvements, and sending the money internationally via wire transfer.
g. The defendants paid a portion of the PPP funds to co-conspirator Bello.

h. The defendants caused transmissions that affected interstate commerce by
sending wire transfers and by accessing and submitting the PPP and EIDL
applications online.

Acts in Furtherance of the Conspiracy

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In furtherance of the conspiracy and to achieve its objects and purpose, the

following acts, among others, were committed in the Eastern District of Texas and

elsewhere.

Preferred Oil and Gas Services fraudulent PPP application

25. On or about March 16, 2021, Preferred Oil and Gas Services, LLC,

( Preferred ) submitted a materially false PPP loan a plication to Amur Equipment

Finance. signed the PPP application as the

primary contact and designated Wells Fargo Bank account number XXXXXX1473, in

the name of Preferred (“Preferred Account 1473”), as the account to receive the loan

funds. On the application, certified that:

The funds will be used to retai orkers and maintain payroll; or make
payments for mortgage interest, rent, utilities, covered operatio s
expenditures, covered property damage costs, covered supplier costs, and
covered worker protection expenditures as specified, under the Paycheck
Protection Program Rules; I understand that if the funds are knowingly used
for unauthorized purposes, the federal government ay hold me legally
liable, such as for charges of fraud.

The Preferred PPP loan account was accessed electronically from IP address

12.11.136.10 .

26. On or about April 8, 2021, Preferred submitted a second materially false

PPP loan application to Amur Equipment Finance to request a second draw on the

o iginal PPP loan. Again, signed the second draw loan PPP application as the

primary contact and designated the Preferred Account as the account to receive the loan

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f nds. Once again, the Preferred PPP loan account was accessed electronically from IP

address 12.11.136.106.

27. The Preferred PPP application falsel stated that the business had 7

employees and had an average monthly payroll expense of approximately $44,533. In

support of the PPP application, submitted documentation, such as a copy of his

driver s license, a voided check, an IRS 1120-S corporate tax return, an IRS 941

Quarte ly federal tax document, financial statements, and an invoice.

28. On or about March 18, 2021, Amur Equipment Finance funde the first

draw PPP loan fo Preferred and sent $111,332 to P eferred Account 1473.

29. On or about June 14, 2021, Amur Equipment Finance funded the second

draw PPP loan for Preferred and sent $111,332 to Prefer ed Account 1473.

Misuse of PPP funds

30. On January 11, 2020, Bello opened a business checking account at Wells

Fargo Bank bearing account number XXXXXX0889, in the name of Ajide Technology

Corporation ( Ajide Account 0889 ). The mailing address for the Ajide Account 0889

was Bello’s residence in McKinney, Texas, in the Eastern District of Texas. Bello was

listed as the sole signer on Ajide Account 0889.

31. On or about March 19, 2021, approximately one day after obtaining the

first draw of the Preferred PPP loan, obtained a cashier’s check drawn from

Preferred Account 1473, made payable to Bello s company, Ajide Technology

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Corporation ( Ajide ), in the amount of $33,399.60. This amount equaled ex ctly 30%

of the PPP loan funds provided to Preferred. Bello was not an employee of Preferred.

32. On March 19, 2021, the cashier s check payable to Ajide was deposited

into Ajide Account 0889. The balance in Ajide Account 0889 prior to the eposit of

$33,399.60 was approximately $6,000.

33. On March 22, 2021, Bello made a $27,795.07 payment to Dovenmuehle

Mortgage, Inc ( Dovenmuehle ). D venmuehle was the mortgage company that, at that

time, held the loan for Bello s primary residence in McKinney, Texas, in the Eastern

District of Texas. Without the $33,399.60 deposit from f, the payment by Bello to

Dovenmeuhle would not have been possible.

34. On April 19, 2021, Bello opened a business checking account at Navy

Federal Credit Union, bearing account number XXXXXX1281, in the name of Ajide,

(“Ajide Account 1281 ). The mailing address for Ajide Account 1281 was in McKinney,

Texas, in the Eastern District of Texas. Bello was listed as the sole signer on Ajide

Account 1281.

35. On or about June 18, 2021, approximately four days after obtaining the

second dr w of the Preferred PPP loan, obtained a cashier s check from the

Preferred Account, made payable to Ajide, in the amount of $33,399.60. This again

equaled exactly 30% of the PPP loan funds provided to Preferred. Again, Bello was not

an employee of Preferred.

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36. On June 25, 2021, the cashier s check payable to Ajide was deposited into

Ajide Account 1281. Bello was the sole signer on Ajide Account 1281. The balance in

Ajide Account 1281 prior to the deposit of $33,399.60 was approximately $8,000.

37. On June 28, 2021, Bello sent five intra-bank transfers totaling $25,000 to

Navy Federal Credit Union account numbe XXXXXX1002 ( Bello Account 1002 ), a

personal checking account held in the name of Bello. The balance in Bello Account 1002

prior to the deposit of $25,000 was app oximately $230. Immediately upon deposit into

Bello Account 1002, Bello transfe red $20,000 into Navy Federal Credit Union account

numbe XXXXXX2297, held in the name of Smooth Multi-Services Platform ( Smooth

Account 2297 ). Bello is the sole signer on Smooth Account 2297.

38. On June 30, 2021, $20,000 of the funds that originated and

transferred through Ajide Account 1281, were combined with other funds that were

recently deposited into the Smooth Account 2297 by Bello into a $75,000 wire transfer,

which was sent inte ationally to Nigeria.

Additional PPP loans that paid 22-32% to Bello

39. Further, in support of the scheme, much like the Preferred loan received by

approximately 22-33% of PPP funds received to Bello. For instance:

a. On or about May 6,2020,
obtained a PPP loan for approximately $43,750 for his cpmpan
Yinxandpartners. Upon receipt of the PPP loan funds, wrote a

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$14,145 check to Ajide, which equaled approximately 32% of the total PPP
loan amount received. Bello was not an employee of Yinxandpartners.

b. On or about May 27, 2020, obtained a
PPP loan for pproximately $30,767 for his company Dfash Transportation,
LLC ( Dfash ). Upon receipt of the PPP loan funds, wrote a $6,000
check to Bello s wife, which equaled approximately 22% of the total PPP loan
amount received. Bello’s wife was not an employee of Dfash. Further, in
support of the PPP loan, submitted a monthly bank statement that had
been altered.

c. On or about May 30, 2020, obtained a PPP
loan for approximately $32,181 for his company Kenny Sunny. Upon recei t
of the PPP loan funds, MH wrote a $9,600 check to Ajide, which equaled
approximately 30% of the total PPP loan amount received. Bello was not an
employee of Kenny Sunny.

On about May 2020,
obtained a PPP loan for approxnmit SS lOforhiscompemy, B-Light
Services. Upon receipt of the PPP loan funds, w ote a $26,793.14
check to Ajide, which equaled 30% of the total PPP loan amount received.
Bello was not an employee of B-Light Services.

e. On or about May 26, 2020, 0 ta ned a
PPP loan fo approximately S O forhiscomi iyVictorMotor s, LLC.
Upon receipt of the PPP loan funds, wrote a $16,050 check to Ajide,
which equaled 30% of the total PPP loan amount received. Bello was not an
employee of Victor Motor s, LLC.

f. On or about September 22, 2020,
obtained a PPP loan for approximatel 62 40 o anyZuby
Automobile. Upon receipt of the PPP loan funds, obtained a
$18,720 cashier’s check made payable to Smooth Multi-Platform, a company
controlled by Bello, which equaled 30% of the total PPP loan amount received.
Bello was not an employee of Zuby Automobile.

g. On or about February 18, 2021, obtained a second draw on the
original PPP loan for approximately $62,400 for Zuby Automobile. Upon
eceipt of the PPP loan funds, obtained a $18,720 cashier’s check
made payable to Ajide, which equaled 30% of the total PPP loan amount
received. Again, Bello was not an employee of Zuby Automobile.

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On about March 2021,
obtained a PPP loan for approximately $116,332 fo his company Ejico, LLC.
Upon receipt of the PPP loan funds, wrote a $34,899 check to Bello,
which equaled 30% of the total PPP loan amount received. Bello was not an
employee of Ejico, LLC.

On or about March 26, 2021, obtained a
PPP loan fo app oximately $106,502 for his company S-O-Y. Upon receipt of
the PPP loan funds, obtained a $31,950.06 cashier s check ma e
payable to Ajide, which equaled 30% of the total PPP loan amount received.
Bello was not an employee of S-O-Y.

j. On or about May 14, 2021, obtained a second PPP loan fo
ap roximately $120,257 for B-Light Services. Upon receipt of the PPP loan
funds, wrote a $37,650 check to Ajide, which equ led 31% f the
total PPP loan amount eceived. Again, Bello was not an employee of B-Light
Services.

k. On o about May 23, 2021, obtained a
PPP loan for approximately $141,373 fo her company Josephine Catering
Service. Upon eceipt of the PPP Ioan funds, lobtained a $42,411.90
cashier s check made payable to Smooth Multi-Services Platform, which
equaled 30% of the total PPP loan amount received. Bello was not an
employee of Josephine Catering Service.

PPP loans obtained by Bello

40. On August 21,2015, Bello opened a personal checking account at

Community America Credit Union bearing account number XXXXXX1701 ( Bello

Account 1701 ). The mailing address for Bello Account 1701 was Bello’s residence in

McKinney, Texas, in the Eastern District of Texas. Bello was listed as the sole signer on

Bello Account 1701.

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41. On May 18,2017, Bello opened a personal checking account at Citib nk,

N.A., bearing ccount number XXXXXX3173 ( Bello Account 3173 ). The mailing

address for Bello Account 3173 was Bello s residence in cKinney, Texas, in the

Eastern District of Texas. Bello was listed as the sole signer on Bello Account 3173.

42. On January 13, 2020, Bello opened a personal checking account at Wells

Fargo Bank bea ing account number XXXXXX0897 ( Bello Account 0897 ). The

mailin address for Bello Account 0897 was Bello’s residence in cKinney, Texas, in

the Eastern District of Texas. Bello was listed as the sole signe on Bello Account 0897.

43. On October 2, 2020, Bello opened a business checkin account at BB&T

bearin account number XXXXXX5834, in the name of Obello, Inc. (“Obello Account

5834 ). The mailing address for Obello Account 5834 was Bello s esidence in

McKinney, Texas, in the Eastern District of Texas. Bello was listed as the sole signer on

Obello Account 5834.

44. Further, in support of the scheme, Bello also obtained multiple PPP loans

fo businesses that he owned an controlled. For instance:

a. On or about July 31, 2020, Bello obtained a first draw PPP loan for
approximately $40,100 for his company Yembell, which was deposited into
Bello Account 1701, which was a personal checking account held by Bello, not
a com any checking account in the n me of Ye bell.

b. On or about January 29, 2021, Bello obtained a second draw PPP loan for
approximately $43,800 for his company Yembell, which was deposited into
Bello Account 5834. In support of the PPP loan draw, Bello submitted a
monthly bank statement that had been altered.

c. On or about May 29, 2020, Bello obtained a first draw PPP loan for

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approximately $52,000 for his company Obello Solutions Corpo ation, which
was deposited into Bello Account 3173. In support of the second PPP loan
draw, Bello submitted a monthly bank statement that had been alte ed.

d. On or about Februa y 25, 2021, Bello obtained a second draw PPP loan for
approximately $115, 00 for his company Obello Solutions Corporation, which
was deposited into Bello Account 0897. In support of the second PPP loan
draw, Bello submitted a monthly bank statement that had been altered.

EIDL loans obtained by Bello

45. On June 18, 2021, Bello opened a business checking account at Navy

Federal Credit Union bearing account number XXXXXX8123, in the name of DOBIT

( DOBIT Account 8123 ). The mailing ad ress for DOBIT Account 8123 was Bello s

residence in McKinney, Texas, in the Eastern District of Texas. Bello was listed as the

sole signer on DOBIT Account 8123.

46. Further, in support of the scheme, Bello also obtained multiple EIDL loans

for businesses that he owned and controlled. For instance:

a. On or about June 2,2020, Bello obtained an EIDL loan for approximately
$90,000 for his company Ajide Technology Corporation, which was deposited
into Ajide Account 0889.

b. On or about June 22, 021, Bello obtained an EIDL loan for app oxi atel
499,900 for his company DOBIT, which was eposited into DOBIT Account
8123.

c. On or about November 30, 2021, Bello obtained additional EIDL loan funds in
the amount of $779,500 for his company DOBIT, which were also deposited
into DOBIT Account 8123.

Misuse of $89,900 in EIDL funds received by ello

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41. On June 2, 2020, the EIDL funds totaling $89,900 were deposited by the

SBA into Ajide Account 0889.

48. In addition, on June 2, 2020, the $26,793.74 check &om |||| (which

re resented 30% of the PPP loan funds paid to B-Light) was also de osited into Ajide

Account 0889. The balance in Ajide Account 0889 prior to these two deposits was

approximately $20,562.47.

49. On June 5, 2020, Bello wrote a $60,800 check made payable to Dodge City

of McKinney for the purchase of a 2020 Dodge Ram 1500 truck, which is registe ed to

Aji e Technology Corporation and Bello at Bello s residence, in McKinney, Texas, in

the Eastern istrict of Texas.

Misuse of $499,900 in EIDL funds received by Bello

50. From June 23, 2021, through June 30, 2021, Bello transfer ed

approximately $261,000 from DOBIT Account 8123 to other personal and business bank

accounts he controlled. During this time rame, there were no other funds deposited into

DOBIT Account 8123.

51. In addition to the outgoing transfers, Bello also made the following

u chases utilizing the EIDL funds that were eposite into DOBIT Account 8123;

a. $72,064.10 payment to Goodleap, LLC, for the purchase of solar panels,
which were installed on Bello’s residence.

b. $50,000 check made payable to Mercedes-Benz of McKinney for the
purchase of a 2020 Mercedes-Benz G550 luxury auto obile, which is
registered to Bello at Bello s residence, in McKinney, Texas, in the Eastern
District of Texas.

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c. Two payments totaling $119,891.32 to Ally Bank to pay off two Dodge
Ram trucks that were pe son lly owned by Bello.

52. The $261,000 of transfers to pe sonal and non-affiliated companies owned

and operated by Bello, combined with the $243,891.32 in purchases made by Bello,

completed depleted the $499,900 EIDL funds deposited into DOBIT Account 8123

All in violation of 18 U.S.C. § 1349.

NOTICE OF INTENT TO SEEK CRIMINAL FORFEITURE

1. The allegations containe in Count One are he eby ealleged and

incorporated by reference as though fully set forth herein for the purpose of alleging

forfeiture to the United States of A erica of certain property in which the efendants

have an interest.

2. Upon conviction of any violation of 18 U.S.C. § 1349, the defendants shall

forfeit to the United States any property, eal or personal, that constitutes or is derived

from proceeds traceable to a violation of any offense constituting specified unlawful

Indictment
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activity, or a conspirac to commit such offense, pursuant to 18 U.S.C. § 981(a)(1)(C)

and 28 U.S.C. § 2461(c).

3. The property that is subject to forfeiture includes, but is not limite to, a

money judgment, and all interest and proceeds trace ble thereto, epresenting the

proceeds of the offenses, for which the defendants are jointly and severally personally

liable.

4. Pursuant to 21 U.S.C. § 853(p), as incorporated by reference by 18 U.S.C.

§ 982(b), if ny of the forfeitable property, or any portion thereof, as a result of any act or

omission of the defendant:

a. cannot be located upon the exercise of due diligence;

b. has been transferred or 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 commin led with other property which cannot be divided without
difficulty;

it is the intent of the United States to seek the forfeiture of other property of the

defendants up to the value of the above-described forfeitable properties, including, but

not limited to, any identifiable property in the name of the defendants.

5. By virtue of the commission of the offense alleged in this indictment, any

and all interest the defendants have in the above-described property is vested in the

United States and hereby forfeite to the United States pursuant to 18 U.S.C.

Indictment
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§§ 981(a)(1)(C) and 28 U.S.C. § 2461(c).

All pursuant to 18 U.S.C. § 981(a)(1)(C) and 28 U.S.C. § 2461(c), and the

procedures set forth at 21 U.S.C. § 853, as made applicable through 18 U.S.C.

§ 982(b)(1).

A TRUE BILL

grand ury FOREPERSON
DAMIEN M. DIGGS
UNITED STATES ATTORNEY

SEAN J. TAYLOR Date
Assistant United States Attorney

Indictment
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IN THE UNITED STATES DISTRICT COURT
FOR THE EASTERN DISTRICT OF TEXAS
SHERMAN DIVISION

SEALED

Case No. 4:23CR
Judge

NOTICE OF PENALTY

Count One

Violation: 18U.S.C. § 1349
(Conspiracy to Commit Wire F aud)

Penalty: A fine of $250,000, or twice the pecuniary ain to the defendant or
loss of the victim(s), whichever is greater; imprisonment for not
more than 20 ye s; and a term of super vised elease of not more
than 3 years.

Special
Assessment: $100

Indictment
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