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Home Source documents Indictment — No. 4:26-cr-00174 (Dkt. 2, E.D. Mo.)

Indictment — No. 4:26-cr-00174 (Dkt. 2, E.D. Mo.)

Summary

Indictment filed April 15, 2026 in the Eastern District of Missouri, case 4:26-cr-00174, against Raymond Porter Jr., David Holmon, Monica Butler, Dana Kelly, Alexander Sampson and Latrice Davis. The grand jury charges that they sent false applications to the SBA and its lenders and obtained more than $8 million in COVID-19 loan money they were not entitled to. The businesses named include Hazelwood Auto Center, Davaire Brands, The Butler Group, Gospel Music Hall of Fame, Inc., Reign Restaurant and a tax preparation firm, The Firm D&B LLC, tied to Kelly. Forfeiture targets four St. Louis properties, a 2020 Aston Martin Vantage, a 2019 Mercedes Sprinter van and a 2021 Cadillac Escalade. These are charges.

Summary drafted by a model from the document's text below 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 — No. 4:26-cr-00174 (Dkt. 2, E.D. Mo.).” Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/indictment-no-4-26-cr-00174-dkt-2-e-d-mo-f6f6130091/, SHA-256 918aded635dd0c9c2c5b3a0089d0403204d97416563c5191a5af9c00da194d42.

Full text

Case: 4:26-cr-00174-MTS-JMB            Doc. #: 2 Filed: 04/15/26           Page: 1 of 41 PageID
                                             #: 51                                       FILED
                                                                                       APR 15 2026
                                                                                     U. S. DISTRICT COURT
                              UNITED STATES DISTRICT COURT                         EASTERN DISTRICT OF MO
                                                                                            ST.LOUIS
                              EASTERN DISTRICT OF MISSOURI
                                    EASTERN DIVISION

 UNITED STATES OF AMERICA,                            )
                                                      )
        Plaintiff,                                    )
                                                      )
 V.                                                   )
                                                      )
                                                             4:26-CR-00174-CMS/JMB
 RAYMOND PORTER, JR.,                                 )
 DAVID HOLMON,                                        )
 MONICA BUTLER,                                       )
 DANA KELLY,                                          )
 ALEXANDER SAMPSON, and                               )
 LA TRICE DA VIS,                                     )
                                                      )
        Defendants.                                   )

                                         INDICTMENT

        The Grand Jury charges that, at all times relevant to this Indictment:

                                           OVERVIEW

        1.      The defendants, RAYMOND PORTER, JR. , DAVID HOLMON, MONICA

BUTLER, DANA KELLY, ALEXANDER SAMPSON, and LATRICE DA VIS, together with

 others known and unknown to the Grand Jury, agreed to and did participate in a scheme to submit

 fraudulent loan applications to the United States Small Business Administration (the "SBA") and

 third-party SBA lenders for the purpose of fraudulently obtaining COVID-19 loan money through

 federal loan programs that were designed to provide emergency financial assistance to American

 small businesses during the height of the pandemic, which President Donald J. Trump declared a

 major disaster and einergency under the Robert T. Stafford Disaster Relief and Emergency

 Assistance Act.

        2.      ln total , through their scheme, the defendants and their confederates fraudulentl y

 obtained more than $8 million in federal COVID-19 loan money to which they were not entitled.
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                                     THE DEFENDANTS

                                       Defendant Porter

          3.    The defendant, RAYMOND PORTER, JR. ("Defendant Porter"), resided within

the Eastern District of Missouri.

          4.    Defendant Porter was a member of a business known as Design Real Estate

 Solutions LLC d/b/a Heartland POS d/b/a Design Retail Equipment Solutions ("Design Retail").

          5.    Defendant Porter was the manager of a business known as Hazelwood Auto Center

LLC ("Hazelwood Auto").

          6.    Defendant Porter was a member of a business known as State Street Phillips LLC

("State Street").

          7.    Defendant Porter was the registered agent of a business known as Unlimited 66

LLC ("Unlimited 66").

                                      Defendant Holmon

          8.    The defendant, DAVID HOLMON ("Defendant Holmon"), resided within the

Eastern District of Missouri.

          9.    Defendant Holmon was a member of a business known as Davaire Brands, LLC

 ("Davaire Brands").

          10.   Defendant Holmon was a member of a business known as Mad Bird 1 LLC ("Mad

Bird").

          11.   Defendant Holmon was a member of a business known as Mezzanine 81 LLC

 ("Mezzanine").

          12.   Defendant Holmon purported to operate under a sole proprietorship known as OMG

 Labs.



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                                            Defendant Butler

        13.     The defendant, MONICA BUTLER ("Defendant Butler"), resided within the

Eastern District of Missouri and the Southern District of lllinois.

        14.     Defendant Butler was a member of a business known as The Butler Group (LLC)

("Butler Group").

        15.     Defendant Butler was a member of a business known as Echelon Media Production

LLC ("Echelon Media").

        16.     Defendant Butler was the incorporator of a business known as Gospel Music Hall

of Fame, Inc. ("Gospel Music Hall of Fame").

                                            Defendant Kelly

        17.     The defendant, DANA KELLY ("Defendant Kelly"), resided within the Eastern

District of Missouri.

        18.     Defendant Kelly was the registered agent of a business known as Reign Restaurant

LLC ("Reign").

        19.     Defendant Kelly was the registered agent of a tax preparation business known as

 The Firm D&B LLC ("The Firm").

                                        Defendant Sampson

        20.     The defendant, ALEXANDER SAMPSON ("Defendant Sampson"), resided

 within the Eastern District of Missouri.

        21.     Defendant Sampson, along with Defendant Kelly, was a signatory on Reign's bank

 accounts.




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                                       Defendant Davis

        22.    The defendant,' LATRICE DA VIS ("Defendant Davis"), resided within the

Eastern District of Missouri.

        23.    Defendant Davis was the registered agent of a business known as Distinq'd

Companies LLC ("Distinq ' d").

        24.    Defendant Davis was the registered agent of a business known as The Headliner's

LLC ("Headliner's").

        25.    Defendant Davis was the registered agent of a business known as LA'z Unique

 Whips & Towing, Incorporated ("LA'z Unique Whips").

                                 COVID-19 LOAN PROGRAMS

        26.    The Coronavirus Aid, Relief, and Economic Security Act (the "CARES Act") was

·a federal law enacted in or around March 2020. The CARES Act was the largest economic stimulus

package in United States history and was designed to, among other things, provide emergency

 funding to American small businesses affected by the COVID-19 pandemic.

        27.    The CARES Act established a new SBA loan program known as the Paycheck

 Protection Program (the "PPP") and made certain changes to a preexisting SBA loan program

 known as the Economic Injury Disaster Loan ("EIDL") program, including changes that expanded

 the types of small businesses eligible for COVID-19 EIDL loans.

                                          PPP Loans

        28.    PPP loans were fully forgivable loans available to eligible small businesses that

 needed financial assistance to stay in operation and keep their workers employed during the

 COVID-19 pandemic.




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        29.     The types of small businesses eligible for PPP loans included businesses and

 nonprofit organizations with not more than 500 employees, as well as self-employed individuals

and individuals who operated under a sole proprietorship or as an independent contractor.

        30.     While the PPP was administered by the SBA, PPP loans were processed, approved,

and funded by third-party SBA lenders that participated in the PPP.

        31.     To obtain a PPP loan, a small business had to submit to a third-party SBA lender a

PPP loan application that was signed by an authorized representative of the business.

        32.     The PPP loan amount for businesses and non-profit organizations with employees

 was based on their average monthly payroll costs during either 2019 or 2020. The PPP loan amount

for self-employed individuals and individuals who operated under a sole proprietorship or as an

 independent contractor was based on their gross income from either 2019 or 2020. The business ' s

 authorized representative was required to provide this information in the business' s PPP loan

 application, along with supporting documentation, such as federal tax documents that the business

 had filed or intended to file with the Internal Revenue Service (the "IRS").

        33.     As part of the PPP loan application, the business's authorized representative was

 required to acknowledge the PPP rules and to make certain affirmative certifications as a condition

 of obtaining the PPP loan. Among other things, the authorized representative was required to

 certify that: (a) the business was in operation on February 15, 2020; (b) current economic

 uncertainty made the loan request necessary to support the ongoing operations of the business; (c)

 all loan proceeds would be used only for specified business-related purposes, such as maintaining

 payroll and making payments for rent, utilities, and operations expenses; and (d) the information

 provided in the loan application and in all supporting documents was true and accurate in all

 material respects.



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        34.    Once a small business submitted a PPP loan application, the third-party SBA lender

processed it. As part of processing the loan application, the lender transmitted data from the

application, including information supplied by the business ' s authorized representative and the

total amount of the loan , to the SBA by means of interstate wire transmission.

        35.    If the PPP loan application was approved , the third-party SBA lender funded the

PPP loan with its own money by electronically transferring the loan proceeds to the

borrower-business' s bank account by means of interstate wire transmission. To encourage lenders

to participate in the PPP and fund PPP loans, the SBA fully guaranteed the loans. Generally, this

meant that, if the borrower-business defaulted on repaying the loan, the SBA would purchase the

borrower-business' s debt from the lender and take on the responsibility of repaying the loan.

        36.    A small business that obtained a PPP loan (referred to as a "First Draw" PPP loan)

could apply for and obtain a second PPP loan (referred to as a "Second Draw" PPP loan) by

submitting to a third-party SBA lender a Second Draw PPP loan application that was signed by an

authorized representative of the business.

        37.        In addition to providing the same information and making the same certifications

as required for the First Draw PPP loan application, in the Second Draw PPP loan application, the

 business's authorized representative was further required to certify that, among other things, the

 business had used the full amount of its First Draw PPP loan only for eligible expenses.

        38.        A small business that obtained a PPP loan could seek to have the principal and

 interest owed on the loan fully forgiven by submitting to the third-party SBA lender that funded

 the loan a PPP loan forgiveness application that was signed by the business' s authorized

 representative.




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         39.     In the forgiveness application, the business's authorized representative was

 required to provide the amount of the PPP loan that the business had spent on payroll costs and to

 certify that, among other things, the information provided in the application was true and correct

 in all material respects.

         40.     If the forgiveness application was approved by the third-party SBA lender, such

 that the loan was fully forgiven , then the SBA repaid to the lender the principal and interest owed

 on the loan, which resulted in the borrower-business owing nothing and having no obligation to

 repay the lender.

                                       COVID-19 EIDL Loans

         41.     COVID-19 EJDL loans were repayable loans with borrower-friendly terms

 available to eligible small businesses that were financially unable to pay their ordinary and

 necessary operating expenses due to economic hardship caused by the COVID-19 pandemic.

         42.     The types of small businesses eligible for COVJD-19 ETDL loans included

 businesses with not more than 500 employees, nonprofit organizations, and individuals who

 operated under a sole proprietorship or as an independent contractor.

         43.     Unlike PPP loans, which were processed, approved, and funded by third-party SBA

 lenders, COVJD-19 EJDL loans were processed, approved, and funded directly by the SBA and

 were not eligible for forgiveness .

         44.     To obtain a COVID-19 EIDL loan, a small business had to submit to the SBA a

 COVlD-19 EIDL loan application that was signed by an authorized representative of the business.

 All COVTD-19 ETDL loan applications had to be submitted online by means of interstate wire

 transmission.




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         45 .    The maximum COVID-19 ElDL loan amount increased over time. The maximum

 COVID-19 EIDL loan amount initially was $150,000, increased to $500,000 on or about April 6,

 2021, and then increased again to $2 million on or about October 8, 2021. As the maximum

 COVTD-19 EIDL loan amount increased, small businesses that previously obtained a COVTD-19

EIDL loan could submit to the SBA a modification request to increase their original loan amount.

         46.     The COVID-19 EIDL loan amount for small businesses was based on their gross

 profit- equal to gross revenues minus cost of goods sold-during the 12 months prior to January

 31 , 2020. The business' s authorized representative was required to provide this information , as

 well as other information, such as the name, date of birth, social security number, and email address

 of the business' s owner, as well as the business ' s number of employees as of January 31 , 2020, in

 the business' s COVID-19 EIDL loan application.

         47.     On some occasions, the SBA required the business' s authorized representative to

 submi~ with the business' s COVID-19 EIDL loan application certain supporting documentation,

 such as bank statements, invoices, and federal tax documents that the business had filed or intended

 to file with the IRS .

         48.     As part of the COVID-19 EIDL loan application, the business's authorized

 representative was required to certify, under penalty of perjury, that all information contained in,

 and submitted with, the loan application was true and correct.

         49.     The COVID-19 EIDL loan application contained a section that stated, "[i]f anyone

 assisted you in completing this application, whether you pay a fee for this service or not, that

 person must enter their information below." In that section, the person who assisted the

 applicant-business in completing the loan application , commonly referred to as a "preparer," was




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 required to provide their name, the name of their business, their phone number, their address, and

 the amount of the fee that they had charged or agreed upon with the applicant.

        50.      After a small business 's COYID-19 EIDL loan application was submitted, and

 before a decision whether to approve or deny the loan application was made, the applicant-business

 could request and obtain up to $15 ,000 in "advance" payments from the SBA, which could be used

 for the same purposes as a PPP loan and did not have to be repaid even if the loan application was

 subsequently denied. The SBA, through the United States Treasury, electronically transferred

 advance payments to the applicant-business's bank account by means of interstate wire

 transmission.

        51.      If the COVID-19 EIDL loan application was approved, the SBA required the

 borrower-business, through its authorized representative, to sign a loan authorization and

 agreement as a condition of obtaining the COYID-19 EIDL loan. As part of that agreement, the

 business's authorized representative was required to promise that, among other things, the business

 would use all the loan proceeds solely as working capital to alleviate economic injury caused by

 the COVID-19 pandemic.

        52.      Onc:e   the   COVID-19    EIDL       loan   application   was   approved   and   the

 borrower-business provided the SBA with all required documentation, such as the signed loan

 authorization and agreement, the SBA, through the United States Treasury, electronically

 transferred the loan proceeds to the business 's bank account by means of interstate wire

 transmission.




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                                        COUNT 1
                     (Conspiracy to Commit Wire Fraud: 18 U.S.C. § 1349)

        53.     The above paragraphs are hereby realleged and incorporated by reference.

        54.     Beginning and ending at an exact time unknown, but including between in or

 around March 2020 and in or around December 2024, within the Eastern District of Missouri and

 elsewhere, the defendants,

                                   RAYMOND PORTER, JR. ,
                                      DAVID HOLMON,
                                     MONICA BUTLER,
                                       DANA KELLY,
                                  ALEXANDER SAMPSON, and
                                      LATRICE DAVIS,

 voluntarily and intentionally combined, conspired, confederated, and agreed with one another and

 others, known and unknown to the Grand Jury, to commit wire fraud in violation of Title 18,

 United States Code, Section 1343 , in that they agreed to participate in a scheme and artifice to

 defraud the SBA and third-party SBA lenders, and to obtain money from the SBA and third-party

 SBA lenders by means of materially false and fraudulent pretenses, representations, and promises,

 and by concealment of material facts, in relation to, and involving benefits authorized , transported,

 transmitted, transferred, disbursed , and paid in connection with, a presidentially declared major

 disaster and emergency (as those terms are defined in section I 02 of the Robert T. Stafford Disaster

 Reliefand Emergency Assistance Act (Title 42, United States Code, Section 5122)), all in violation

 of Title 18, United States Code, Section 1349.

                                    The Object of the Conspiracy

         55.    The object of the conspiracy to commit wire fraud was to fraudulentl y obtain

 COVID-19 loa11 money by submitting to the SBA and third-party SBA lenders fraudulent PPP and




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 COVID-19 EIDL loan applications that contained materially false representations and promises

 and concealed material facts.

                            The Manner and Means of the Conspiracy

        It was part of the conspiracy to commit wire fraud that:

        56.     Defendant Porter and Defendant Holmon, with the assistance of Defendant Davis,

 worked together to prepare and submit fraudulent PPP and COVID-19 EIDL loan applications for

 small businesses, including for their own businesses and for the businesses of their confederates,

 such as Defendant Butler, Defendant Kelly, and Defendant Sampson.

        57.     Among other methods of communication, Defendant Davis used the email account

 latrice.pppmoney@gmail.com to communicate with Defendant Porter and Defendant Holmon

 regarding the fraudulent PPP and COVID-19 EIDL loan applications that the three of them

 prepared and submitted for small businesses.

        58.     In exchange for preparing and submitting fraudulent PPP and COVID-19 EIDL

 loan applications for their confederates' small businesses, Defendant Porter and Defendant

 Holmon charged their confederates fees that were to be paid from the loan proceeds-typically

 between 10-20% of the proceeds- if their confederates' fraudulent loan applications were

 approved and funded. To conceal that those payments were compensation for their preparation and

 submission of fraudulent PPP and COVID-19 EIDL loan applications, on numerous occasions,

 Defendant Porter and Defendant Holmon instructed their confederates to write false information

 in the memo line of the payments, such as that the payments were for equipment or consulting

 services.




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         59.      Defendant Porter and Defendant Holmon, in turn, paid Defendant Davis a portion

 of those fees as compensation for her assistance with preparing and submitting the fraudulent loan

 applications .

         60.      Defendant Porter and Defendant Holmon directed their confederates, including

 Defendant Butler and Defendant Kelly, to refer to them other people who were seeking COVID-19

 loan money so that Defendant Porter and Defendant Holmon, with the assistance of Defendant

 Davis, could prepare and submit fraudulent PPP and COVID-19 EIDL loan applications for those

 people ' s small businesses. On some occasions when a referral resulted in a fraudulent loan

 application being approved and funded , the confederate who made the referral to Defendant Porter

 and Defendant Holmon received a portion of the loan proceeds, either directly from the person

 whose business obtained the fraudulent loan or from Defendant Porter and Defendant Holmon

 after they received their fees for preparing and submitting the fraudulent loan application.

         61 .     So that Defendant Porter and Defendant Holmon, with the assistance of Defendant

 Davis, could prepare and submit fraudulent PPP and COVID-19 EIDL loan applications for their

 confederates ' small businesses, Defendant Porter and Defendant Holmon requested their

 confederates' personally identifiable information, such as their confederates ' dates of birth, social

 security numbers, and home addresses, as well as information about their confederates' businesses,

 such as their confederates' businesses' names, employer identification numbers, email addresses

 and passwords, and banking information.

         62.      Defendant Porter and Defendant Holmon requested their confederates' businesses'

 email addresses and passwords so that Defendant Porter and Defendant Holmon could use the

 email addresses to impersonate their confederates while communicating with the SBA and

 third-party SBA lenders regarding their confederates' fraudulent PPP and COVID-19 EIDL loan



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 applications. On numerous occasions, including when their confederates did not have business

 email addresses, oftentimes because their confederates' businesses were not operational,

 Defendant Porter, Defendant Holmon, and Defendant Davis created fictitious email addresses for

 those businesses. In addition, Defendant Porter and Defendant Holmon also created fictitious email

 addresses for certain of their own businesses.

        63.     Further, on numerous occasions when the small businesses for which they prepared

 and submitted fraudulent PPP and COVlD-19 EIDL loan applications did not have websites or

 bank accounts, Defendant Porter and Defendant Holmon created fictitious websites for those

 businesses to make it falsely appear that those businesses were operational, and opened, and

 instructed their confederates to open, business bank accounts for the sole purpose of using those

 accounts to receive electronic transfers of fraudulently obtained PPP and COVID-19 EIDL loan

 proceeds from the SBA and third-pa1iy SBA lenders.

        64.     In some instances when their confederates did not have small businesses, Defendant

 Davis registered sham businesses, such as Headliner's, for their confederates with the Missouri

 Secretary of State so that Defendant Davis, Defendant Porter, and Defendant Holmon could

 prepare and submit fraudulent PPP and COVID-19 EIDL loan applications for those businesses.

        65 .     While preparing fraudulent PPP and COVID-19 EIDL loan applications for their

 confederates' small businesses, Defendant Porter and Defendant Holmon rarely requested

 information and supporting documentation relating to their confederates' businesses' average

 monthly payroll costs, gross income, or gross profit, even though, as Defendant Porter and

 Defendant Holmon knew, that information-and only that information- determined the PPP and

 COVID-19 EIDL loan amounts for which their confederates' businesses were potentially eligible.




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        66.      Some confederates for whom Defendant Porter, Defendant Holmon, and Defendant

 Davis prepared and submitted fraudulent PPP and COVID-19 EIDL loan applications, such as

 Defendant Butler, Defendant Kelly, and Defendant Sampson, knew that such information was

 required to be provided to the SBA and third-party SBA lenders as part of their small businesses'

 loan applications, and further knew that Defendant Porter and Defendant Holmon planned to

 falsify such information for their businesses ' loan applications.

        67.      Other people for whom Defendant Porter, Defendant Holmon, and Defendant Davis

 prepared and submitted fraudulent PPP and COVID-19 EIDL loan applications were unaware that

 such information was required to be provided to the SBA and third-party SBA lenders because

 Defendant Porter and Defendant Holmon concealed that requirement from them and provided

 them with false infonnation, such as by telling them that eligibility for PPP and COVID-19 EIDL

 loans was determined based solely on the business owner' s credit score.

        68.      For each of the small businesses for which they prepared and submitted fraudulent

 PPP and COVID-19 EIDL loan applications, including their own businesses, Defendant Porter,

 Defendant Holmon, and Defendant Davis falsely inflated those businesses' average monthly

 payroll costs, gross income, or gross profit figures in the fraudulent loan applications to increase

 the loan amounts .for which those businesses were eligible. But for those materially false

 representations regarding those businesses ' payroll costs, gross income, or gross profit, none of

 those businesses would have been eligible for the PPP and COVID-19 EIDL loan amounts they

 obtained, and many would not have been eligible to obtain any PPP and COVID-19 EIDL loan

 money at all.

         69.     When supporting documentation was required to be submitted with those

 fraudulent loan applications, Defendant Porter, Defendant Holmon, and Defendant Davis



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 oftentimes created and supplied the SBA and third-pa1iy SBA lenders with falsified documents,

 such as falsified federal tax documents, falsified payroll records, falsified bank statements, and

 falsified invoices.

         70.     In each of the fraudulent PPP and COVID-19 EIDL loan applications that

 Defendant Porter, Defendant Holmon, and Defendant Davis prepared and submitted for their own

 small businesses, they falsely represented that the loan proceeds would be used only for authorized

 purposes, despite knowing that they were going to use most, and sometimes all , of the loan

 proceeds for unauthorized purposes.

         71.     In addition, in each of the fraudulent PPP and COVID-19 EIDL loan applications

 that Defendant Porter and Defendant Holmon, with the assistance of Defendant Davis, prepared

 and submitted for their confederates ' small businesses, they falsely represented that the loan

 proceeds would be used only for authorized purposes, despite knowing that a portion of the loan

 proceeds would be used for the unauthorized purpose of paying the fees charged by Defendant

 Porter and Defendant Holmon for preparing and submitting the fraudulent loan applications.

         72.     In numerous fraudulent PPP and COVJD-19 EIDL loan applications that they

 prepared and submitted for their own small businesses, Defendant Porter, Defendant Holmon, and

 Defendant Davis concealed their majority ownership of those businesses by falsely representing

 that someone else was the majority owner of their businesses, such as by identifying the majority

 owner as one of their family members, in order to prevent the SBA and third-party SBA lenders

 from learning that they were the ones who would receive the loan proceeds if the applications were

 approved and funded. Likewise, in multiple fraudulent PPP and COVID-19 EIDL loan

 applications that they prepared and submitted for their confederates' small businesses, Defendant

 Porter, Defendant Holmon, and Defendant Davis falsely represented that someone other than their



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 confederates was the owner of those businesses, such as by identifying the owner as one of their

 confederates' fam ily members or associates, including on occasions when their confederates'

 credit scores would have caused their confederates ' businesses to be ineligible for PPP and

 COVID-19 EIDL loans.

        73 .    Further, in numerous fraudulent COVID-19 EIDL loan applications that Defendant

 Porter and Defendant Holmon, with the assistance of Defendant Davis, prepared and submitted for

 their own small businesses, as well as for the small businesses of their confederates, they listed

 Defendant Porter' s information in the "preparer" section of the loan applications so that Defendant

 Porter could communicate directly with the SBA regarding the fraudulent loan applications, and

 in each of those fraudulent loan applications they falsely represented that Defendant Porter had

 charged a fee of $500 or less. In truth and in fact, Defendant Porter typically charged thousands of

 dollars in fees per fraudulent loan application.

        74.     At Defendant Porter' s direction, Defendant Kelly knowingly caused falsified

 federal tax documents to be filed with the IRS through her tax preparation business, The Firm, in

 an effort to conceal the fraudulent nature of the PPP and COVID-19 EIDL loans that Defendant

 Porter and Defendant Holmon obtained for certain of their own small businesses, as well as for

 certain of the small businesses of Defendant Butler, Defendant Kelly, and Defendant Sampson.

        75 .    For some of the fraudulent PPP loans that Defendant Porter and Defendant Holmon

 obtained for certain of their own small businesses, as well as those of their confederates, including

 Defendant Butler, Defendant Kelly, and Defendant Sampson, Defendant Porter and Defendant

 Holmon prepared and submitted to third-party SBA lenders fraudulent PPP loan forgiveness

 applications, including falsified supporting documentation, which in numerous instances resulted

 in the lenders approving the forgiveness applications and absolving Defendant Porter, Defendant



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 Holmon, and their confederates of having to repay any of the PPP loan proceeds that they

 fraudulently obtained.

                                   The Scope of the Conspiracy

         76.    Defendant Porter and Defendant Holmon, with the assistance of Defendant Davis,

 prepared and submitted more than 40 fraudulent PPP and COVID-19 EIDL loan applications for

 their own small businesses and for their confederates ' small businesses, including the businesses

 of Defendant Butler, Defendant Kelly, and Defendant Sampson, that were approved and funded

 by the SBA and third-party SBA lenders.

         77.    Based on those fraudulent loan applications, the defendants and their confederates

 fraudulently obtained a total of more than $8 million in COVID-19 loan money, as follows:



    84 Auto Salez               PPP (First Draw)             Seattle Bank                $59,083
    84 Auto Salez              PPP (Second Draw)             Seattle Bank                $59,083
    Butler Group                COVID-19 EIDL                    SBA                    $887,900
   Chambers Park                PPP (First Draw)          Customers Bank                $144,411
Cooper Consulting Firm          COVTD-19 ETDL                    SBA                    $150,000
   Davaire Brands               COVID-19 EIDL                    SBA                     $85,700
   Davaire Brands               PPP (First Draw)          Milestone Bank                 $44,995
       Deenbee                  COVID-19 EIDL                    SBA                    $150,000
       Deenbee                  PPP (First Draw)       First Bank of the Lake           $122,270
  Dela Creme Studio             COVID-19 EIDL                    SBA                     $71,500
    Design Retail               COVTD-19 EIDL •                  SBA                    $150,000
    Design Retai I              PPP (First Draw)           Kabbage, Inc.                 $48,803
    Design Retail              PPP (Second Draw)          Amur Equipment                $130,950
                                                            Finance, Inc.
        Distinq ' d              COVTD-19 ETDL                   SBA                      $96,500
      Echelon Media              PPP (First Draw)      First Bank of the Lake            $266,148
       EZ ID Tags                COVID-19 EIDL                   SBA                      $64,300
     Global Watchdog             COVTD-19 EJDL                   SBA                     $106,000
     Global Watchdog             PPP (First Draw)         Amur Equipment                 $114,737
                                                            Finance, Inc.
     Hazelwood Auto              COVID-19 EIDL                   SBA                     $150,000

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             Headliner's            COVID-19 EIDL                  SBA                     $150,000
                IDA                 COVID-19 EIDL                  SBA                     $122,300
   Inspired Lives Foundation        COVID-19 EIDL                  SBA                      $94,800
      J. Corley & Associates        COVID-19 EIDL                  SBA                     $150,000
Jackson Engineering Consultants     COVID-19 EIDL                  SBA                      $84,500
        LA'z Unique Whips           COVID-19 EIDL                  SBA                     $122,300
              Mad Bird              COVID-19 EIDL                  SBA                     $150,000
             Mezzanine              COVID-19 EIDL                  SBA                     $150,000
               Napps                PPP (First Draw)         Customers Bank                $162,929
             OMGLabs                COVID-19 EIDL                  SBA                     $112,000
 Platform Health Care Solutions     PPP (First Draw)      First Bank of the Lake           $133,852
       Premium Prestigious          COVID-19 EIDL                  SBA                     $150,000
          Prince Collection         COVID-19 EIDL                  SBA                     $150,000
               Reign                PPP (First Draw)       ltria Ventures LLC              $397,210
             Right Care             COVID- 19 EIDL                 SBA                     $500,000
               Saikap               COVID-19 EIDL                  SBA                     $500,000
         Salaam Enterprises         COVID-19 EIDL                  SBA                     $150,000
Salsa Made Ridiculously Simple      COVID-19 EIDL                  SBA                      $24,100
           SFP Enterprises          COVID-19 EIDL                  SBA                     $390,500
        Simon Technologies          COVID-19 EIDL •                SBA                     $150,000
        Simon Technologies          PPP (First Draw)         Amur Equipment                $101,270
                                                               Finance, Inc.
      South Side Vending            COVID-19 EIDL                  SBA                     $105,600
          State Street              COVID-19 EIDL                  SBA                     $150,000
          State Street              PPP (First Draw)          Northeast Bank               $133,852
         Swaggy Tags                COVID-19 EIDL                  SBA                     $500,000
      The Health Centers            COVID-19 EIDL                  SBA                     $500,000
         Unlimited 66               COVID-19 EIDL                  SBA                     $150,000
           TOTAL                                                                          $8,387,593

            78.    Of the approximately $8 million in fraudulently obtained COVID-19 loan money,

     Defendant Porter and Defendant Holmon directly and personally received a total of more than $1.4

     million of that money from the fraudulent PPP and COVID-19 EIDL loan applications that they

     prepared and submitted for their own small businesses, plus a total of more than $900,000 of that



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 money through the fees that they charged their confederates for preparing and submitting

 fraudulent PPP and COVID-19 EIDL loan applications for their confederates ' small businesses.

        79.     After fraudulently obtaining that COVID-19 loan money, Defendant Porter,

 Defendant Holmon, Defendant Butler, Defendant Kelly, Defendant Sampson, and their

 confederates used most of that money for unauthorized purposes, including to, among other things,

 purchase personal vehicles, make personal payments to themselves, pay personal debts and bills,

 fund home renovations, buy designer merchandise, and cover expenses of businesses other than

 the ones to which the money was lent.

        All in violation of Title 18, United States Code, Section 1349.

                                       COUNTS 2-21
                             (Wire Fraud: 18 U.S.C. §§ 1343 and 2)

        80.     The above paragraphs are hereby realleged and incorporated by reference.

                                            The Scheme

        81 .    Beginning and ending at an exact time unknown, but including between in or

 around March 2020 and in or around December 2024, within the Eastern District of Missouri and

 elsewhere, the defendants, while being aided, abetted, counseled, encouraged, and induced by one

 another and others, known and unknown to the Grand Jury, and with the intent to defraud,

 knowingly, voluntarily, and intentionally devised, joined, and participated in a scheme and artifice

 to defraud the SBA and third-party SBA lenders, and to obtain money from the SBA and

 third-party SBA lenders by means of materially false and fraudulent pretenses, representations,

 and promises, and by concealment of material facts, in relation to, and involving benefits

 authorized, transported, transmitted, transferred, disbursed, and paid in connection with, a

 presidentially declared major disaster and emergency (as those terms are defined in section I 02 of




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 the Robert T. Stafford Disaster Relief and Emergency Assistance Act (Title 42, United States

 Code, Section 5122)), as described above and below.

                                The Manner and Means of the Scheme

        82.        In addition to the same manner and means as the conspiracy described above, it was

 part of the scheme that:

                            Defendant Porter's Fraudulent COVID-19 Loans

        83.        Defendant Porter, with the assistance of Defendant Holmon, submitted numerous

 fraudulent PPP and COVID-19 EIDL loan applications to the SBA and third-party SBA lenders

 for his small businesses, Design Retail, Hazelwood Auto, State Street, and Unlimited 66, including

 the following :



     March 30, 2020                                                                 $150,000
                                                      PPP First Draw                 $48,803
                                                     PPP Second Draw                $130,950
                                Unlimited 66          COVID-19 EIDL                 $150,000
                               Hazelwood Auto         COVID-19 EIDL                 $150,000
                                 State Street         COVID-19 EIDL                 $150,000
                                 State Street         PPP First Draw                $133,852
        TOTAL                                                                       $913,605

         84.       On or about March 30, 2020, Defendant Porter submitted a fraudulent COVID-19

 ElDL loan application to the SBA for Design Retail. In that fraudulent loan application, Defendant

 Porter falsely inflated Design Retail ' s gross profit during the 12 months prior to January 31, 2020

 and further falsely represented, among other things, that his son, rather than himself, was the

 majority owner of Design Retail. Defendant Porter Iisted himself in the "preparer" section of the

 fraudulent loan application so that he could communicate directly with the SBA regarding the

 application. As a condition of obtaining a COVlD-19 EIDL loan for Design Retail, Defendant

 Porter forged his son ' s name on a loan authorization and agreement, in which Defendant Porter


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 falsely represented that all loan proceeds would be used solely as working capital to alleviate

 economic injury caused by the COVTD-19 pandemic. Further, to conceal the false representations

 about Design Retail ' s gross profit, after the fraudulent loan application was approved and just

 before Defendant Porter submitted a fraudulent COVID-19 EIDL loan modification request to the

 SBA, Defendant Porter directed Defendant Kelly to cause falsified federal tax documents for

 Design Retail to be filed with the IRS through her tax preparation business, The Firm , which she

 did.

        85 .    On or about July 8, 2020, Defendant Porter submitted a fraudulent First Draw PPP

 loan application to third-party SBA lender Kabbage, Inc. ("Kabbage") for Design Retail. In that

 fraudulent loan application, Defendant Porter falsely inflated Design Retail's average monthly

 payroll costs, which he supported by supplying Kabbage with falsified federal tax documents, and

 further falsely represented, among other things, that his son, rather than himself, was the majority

 owner of Design Retail and that all loan proceeds would be used only for certain business-related

 purposes, specifically maintaining payroll and making lease and mortgage interest payments.

        86.     On or about April 9, 2021, Defendant Porter submitted a fraudulent Second Draw

 PPP loan application to third-party SBA lender Amur Equipment Finance, Inc. ("Amur") for

 Design Retail. In that fraudulent loan application, Defendant Porter falsely inflated Design Retail ' s

 average monthly payroll costs, which he supported by supplying Amur with falsified federal tax

 documents, and further falsely represented, among other things; that his son , rather than himself,

 was the majority owner of Design Retail and that Design Retail had used the full amount of its

 First Draw PPP loan only for eligible expenses and would similarly use the proceeds of its Second

 Draw PPP loan only for eligible expenses.




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        87.     On or about July 15, 2020, Defendant Porter submitted a fraudulent COVID-19

 EIDL loan application to the SBA for Unlimited 66. In that fraudulent loan application, Defendant

 Porter falsely inflated Unlimited 66' s gross profit during the 12 months prior to January 31, 2020

 and further falsely represented, among other things, that his father, rather than himself, was the

 majority owner ofU nlimited 66. As a condition of obtaining a COVID-19 EIDL loan for Unlimited

 66, Defendant Porter forged his father ' s name on a loan authorization and agreement, in which

 Defendant Porter falsely represented that all loan proceeds would be used solely as working capital

 to alleviate economic injury caused by the COVID-19 pandemic. Less than a week before

 submitting the fraudulent loan application, Defendant Porter opened a business bank account for

 Unlimited 66, for which he was the sole signatory. Further, on or about the same date that

 Defendant Porter submitted the fraudulent loan application, Defendant Holmon, at Defendant

 Porter' s direction, created a fictitious website for Unlimited 66 to make it falsely appear that

 Unlimited 66 was operational.

        88.     On or about August 25 , 2020, Defendant Porter submitted a fraudulent COVID-19

 EIDL loan application to the SBA for Hazelwood Auto. In that fraudu lent loan application,

 Defendant Porter falsely inflated Hazelwood Auto ' s gross profit during the 12 months prior to

 January 31, 2020 and further falsely represented, among other things, that his wife, rather than

 himself, was the majority owner of Hazelwood Auto. Defendant Porter listed himself in the

 "preparer" section of the fraudulent loan application so that he could communicate directly with

 the SBA regarding the application. As a condition of obtaining a COVID-19 EIDL loan for

 Hazelwood Auto, Defendant Porter forged his wife's name on a loan authorization and agreement,

 in which Defendant Porter falsely represented that all loan proceeds would be used solely as

 working capital to alleviate economic injury caused by the COVID-19 pandemic. Less than a week



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 before submitting the fraudulent loan application, Defendant Porter opened a business bank

 account for Hazelwood Auto, for which he was the sole signatory. Further, on or about the day

 before Defendant Porter submitted the fraudulent loan application, Defendant Holmon, at

 Defendant Porter's direction , created a fictitious website for Hazelwood Auto to make it falsely

 appear that Hazelwood Auto was operational.

        89.     On or about September 3, 2020, Defendant Porter submitted a fraudulent

 COVID-19 EIDL loan application to the SBA for State Street. In that fraudulent loan application,

 Defendant Porter falsely inflated State Street's gross profit during the 12 months prior to January

 31 , 2020 and further falsely represented, among other things, that his mother, rather than himself,

 was the majority owner of State Street. Defendant Porter listed himself in the "preparer" section

 of the fraudulent loan application so that he could communicate directly with the SBA regarding

 the application. As a condition of obtaining a COVID-19 EIDL loan for State Street, Defendant

 Porter forged his mother's name on a loan authorization and agreement, in which Defendant Porter

 falsely represented that all loan proceeds would be used solely as working capital to alleviate

 economic injury caused by the COVID-19 pandemic. Less than a week before submitting the

 fraudulent loan application, Defendant Porter opened a business bank account for State Street, for

 which he was the sole signatory. Further, less than a week before Defendant Porter submitted the

 fraudulent loan application, Defendant Holmon, at Defendant Porter's direction, created a

 fictitious website for State Street to make it falsely appear that State Street was operational.

        90.     On or about April 21 , 2021, Defendant Porter submitted a fraudulent First Draw

 PPP loan application for State Street to third-party SBA lender Northeast Bank. In that fraudulent

 loan application, Defendant Porter falsely inflated State Street's average monthly payroll costs,

 which he supported by supplying Northeast Bank with falsified federal tax documents, and further



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                                              #: 74




 falsely represented, among other things, that his mother, rather than himself, was the majority

 owner of State Street and that all loan proceeds would be used only for certain business-related

 purposes, specifically maintaining payroll and making payments for rent and utilities.

        91.     Relying on the truth of Defendant Porter' s false representations and fraudulent

 documentation, the SBA and the third-party SBA lenders approved each of those loan applications.

 Following the approval of those fraudulent loan applications, the SBA and the third-party SBA

 lenders electronically transferred a total of more than $900,000 in PPP and COVID-19 EIDL loan

 proceeds to the business bank accounts of Defendant Porter's businesses.

        92.     Contrary to the material misrepresentations that Defendant Porter made regarding

 how his businesses ' loan proceeds would be used, Defendant Porter used his fraudulently obtained

 loan proceeds for unauthorized purposes, including by transferring nearly all the proceeds of

 Hazelwood Auto, State Street, and Unlimited 66 to his personal Zelle account and to Design

 Retail ' s business bank account. Defendant Porter then used the proceeds to pay for personal

 expenses, such as renovation work on his personal residence, debt owed on his personal residence

 and an investment property, personal restaurant and grocery purchases, and personal bills.

        93.     Defendant Porter later fraudulently applied for and received full forgiveness of each

 of the three PPP loans that he fraudulently obtained, meaning that he was relieved of the obligation

 to repay those PPP loans.

                        Defendant Holmon ' s Fraudulent COVID-19 Loans

        94.     Defendant Holmon, with the assistance of Defendant Porter, submitted numerous

 fraudulent PPP and COVJD-19 EJDL loan applications to the SBA and a third-party SBA lender

 for his small businesses, Davaire Brands, Mad Bird, Mezzanine, and OMG Labs, including the

 following :



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                                              #: 75




                                                                                   $85 ,700
     June 14, 2020           Davaire Brands             PPP First Draw             $44,995
     June 20, 2020            OMG Labs                  COVID-19 EIDL             $112,000
                              Mezzanine                 COVID-19 EIDL             $150,000
                               Mad Bird                 COVID-19 EIDL             $150,000
       TOTAL                                                                      $542,695

        95.     On or about April 14, 2020, Defendant Holmon submitted a fraudulent COVID-19

 EIDL loan application to the SBA for Davaire Brands. In that fraudulent loan application,

 Defendant Holmon falsely inflated Davaire Brands ' gross profit during the 12 months prior to

 January 31 , 2020 and futiher falsely represented, among other things, that his mother, rather than

 himself, was the majority owner of Davaire Brands. As a condition of obtaining a COVID-19

 EIDL loan for Davaire Brands, Defendant Holmon forged his mother' s name on a loan

 authorization and agreement, in which Defendant Holmon falsely represented that all loan

 proceeds would be used solely as working capital to alleviate economic injury caused by the

 COVID-19 pandemic. Further, to conceal the false representations about Davaire Brands' gross

 profit, after the fraudulent loan application was approved and just before Defendant Holmon

 submitted a fraudulent COVID-19 EIDL loan modification request to the SBA, Defendant Porter,

 with Defendant Holmon ' s knowledge and authorization, directed Defendant Kelly to cause

 falsified federal tax documents for Davaire Brands to be filed with the IRS through her tax

 preparation business, The Firm , which she did.

        96.     On or about June 14, 2020, Defendant Holmon submitted a fraudulent First Draw

 PPP loan application to third-party SBA lender Milestone Bank for Davaire Brands. In that

 fraudulent loan application, Defendant Holmon falsely inflated Davaire Brands' average monthly

 payroll costs, which he supported by supplying the SBA with falsified federal tax documents, and

 further fal sely represented, among other things, that his mother, rather than himself, was the


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                                               #: 76




 majority owner of Davaire Brands and that all loan proceeds would be used only for certain

 business-related purposes, specifically maintaining payroll and making payments for rent and

 utilities.

          97.   On or about June 20, 2020, Defendant Holmon submitted a fraudulent COVTD-19

 EIDL loan application to the SBA for OMG Labs. In that fraudulent loan application, Defendant

 Holmon falsely inflated OMG Labs' gross profit during the 12 months prior to January 31 , 2020.

 As a condition of obtaining a COVID-19 EIDL loan for OMG Labs, Defendant Holmon falsely

 represented in a loan authorization and agreement that all loan proceeds would be used solely as

 working capital to alleviate economic injury caused by the COVID-19 pandemic.

          98.   On or about July 15, 2020, Defendant Holmon submitted a fraudulent COVID-19

 EIDL loan application to the SBA for Mezzanine. In that fraudulent loan application, Defendant

 Holmon falsely inflated Mezzanine's gross profit during the 12 months prior to January 31, 2020

 and further falsely represented , among other things, that one of his associates, rather than himself,

 was the majority owner of Mezzanine. As a condition of obtaining a COVID-19 EIDL loan for

 Mezzanine, Defendant Holmon forged his associate ' s name on a loan authorization and agreement,

 in which Defendant Holmon falsely represented that all loan proceeds would be used solely as

 working capital to alleviate economic injury caused by the COVID-19 pandemic. Less than a week

 before submitting the fraudulent loan application, Defendant Holmon opened a business · bank

 account for Mezzanine, for which he was the sole signatory. Further, on or about the same date

 that Defendant Holmon submitted the fraudulent loan application, Defendant Holmon created a

 fictitious website for Mezzanine to make it falsely appear that Mezzanine was operational.

          99.   On or about August 3, 2020, at Defendant Holman ' s direction, Defendant Porter

 submitted a fraudulent COVID-19 EIDL loan application to the SBA for Mad Bird. As Defendant



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                                                #: 77




 Holmon had instructed, in that fraudulent loan application , Defendant Porter falsely inflated Mad

 Bird ' s gross profit during the 12 months prior to January 31 , 2020 and further falsely represented ,

 among other things, that Defendant Holman ' s father, rather than Defendant Holmon, was the

 majority owner of Mad Bird. Defendant Porter listed himself in the "preparer" section of the

 fraudulent loan application so that he could communicate directly with the SBA regarding the

 application. As a condition of obtaining a COVID-19 EIDL loan for Mad Bird, Defendant Porter,

 at Defendant Holman's direction, forged Defendant Holman ' s father's name on a loan

 authorization and agreement, in which Defendant Porter, with Defendant Holman ' s knowledge

 and authorization, falsely represented that all loan proceeds would be used solely as working

 capital to alleviate economic injury caused by the COVID-19 pandemic. Less than a week before

 causing Defendant Porter to submit the fraudulent loan application, Defendant Holmon opened a

 business bank account for Mad Bird, for which Defendant Holmon was the sole signatory. Further,

 less than a week before Defendant Holmon caused Defendant Porter to submit the fraudulent loan

 application, Defendant Holmon created a fictitious website for Mad Bird to make it falsely appear

 that Mad Bird was operational.

         100.    Relying on the truth of Defendant Holman ' s fal se representations and fraudulent

 documentation, the SBA and third-party SBA lender Milestone Bank approved each of those loan

 applications. Following the approval of those fraudulent loan applications, the SBA and third-party

 SBA lender Milestone Bank electronically transferred a total of more than $500,000 in PPP and

 COVID-19 EIDL loan proceeds to the business bank accounts of Defendant Holman ' s businesses

 and to one of Defendant Holmon ' s personal bank accounts.

         101 .   Contrary to the material misrepresentations that Defendant Holmon made regarding

 how his businesses' loan proceed s would be used, Defendant Holmon used his fraudulentl y



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                                                                                                        #: 78




    obtained loan proceeds for unauthorized purposes, including to pay for personal expenses, such as

    debt owed on his personal residence and a personal vehicle purchase for nearly $100,000.

                             102.                  Defendant Holmon later fraudulently applied for and received full forgiveness of

    the PPP loan that he fraudulently obtained, meaning that he was relieved of the obligation to repay

    that PPP loan.

                                                                  Defendant Butler' s Fraudulent COVID-19 Loans

                             103.                  Defendant Butler caused Defendant Porter and Defendant Holmon to submit

    numerous fraudulent PPP and COVTD-19 EJDL loan applications to the SBA and a third-party

    SBA lender for her small businesses, Butler Group and Echelon Media, including the following:

,!~prox1mate-6aie'1 ~::;y"'~/Ap'pifcantP"f~ .-;'"f\'·, '· ~:~-,. • t'o-an Type :•::"t::!:' ·--~ ;.-Loaii Amouri(~l
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                                                                                                                                                                                              ~it
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             July 8, 2020                      Butler Group                                                                                COVJD-19 EIDL                                                  $160,000
           February 10, 2022                   Butler Group                                                                                COVID-19 EIDL                                                  $350,000
                                                                                                                                            (Modification)
                April 19, 2022                                                Butler Group                                                 COVID-19 EIDL                                                   $377,900
                                                                                                                                            (Modification)
                April 22, 2021                                              Echelon Media                                                  PPP (First Draw)                                                 $266,148
                  TOTAL                                                                                                                                                                                    $1,154,048

                             104.                   On or about July 8, 2020, Defendant Butler caused Defendant Holmon, with the

    assistance of Defendant Porter, to submit a fraudulent COVID-19 EIDL loan application to the

    SBA for Butler Group. As Defendant Butler knew would occur, in that fraudulent loan application,

    Defendant Holmon falsely inflated Butler Group' s gross profit during the 12 months prior to

    January 31 , 2020, which he supported by supplying the SBA with falsified federal tax documents.

    In connection with the fraudulent loan application, Defendant Holmon also created a fictitious

    email address for Butler Group, which Defendant Holmon listed in the application as Defendant

    Butler' s email address so that he could communicate directly with the SBA regarding the

    application. Further, as a condition of obtaining a COVID-19 EIDL loan for Butler Group,



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 Defendant Holmon, with Defendant Butler's knowledge and authorization, falsely represented in

 a loan authorization and agreement that all loan proceeds would be used solely as working capital

 to alleviate economic injury caused by the COVID-19 pandemic.

        105.    On or about February I 0, 2022, Defendant Butler caused Defendant Porter to

 submit a fraudulent COVID-19 EIDL loan modification request to the SBA for Butler Group. As

 part of the fraudulent modification request, and with Defendant Butler' s knowledge and

 authorization, Defendant Porter supplied the SBA with a second set of falsified federal tax

 documents that falsely inflated Butler Group ' s gross profit during the 12 months prior to January

 31 , 2020. To conceal the false representations made in the original loan application about Butler

 Group ' s gross profit and to increase the likelihood that the fraudulent modification request would

 be approved, before Defendant Porter submitted the modification request, Defendant Porter

 directed Defendant Kelly to cause falsified federal tax documents for Butler Group to be filed with

 the IRS through her tax preparation business, The Firm, which she did.

        106.    On or about April 19, 2022, Defendant Butler caused Defendant Porter to submit a

 second fraudulent COVID-19 EIDL loan modification request to the SBA for Butler Group. As

 part of the second fraudulent modification request, and with Defendant Butler' s knowledge and

 authorization , Defendant Porter supplied the SBA with numerous falsified documents, such as

 fal sified invoices and a third set of falsified federal tax documents that falsely inflated Butler

 Group' s gross profit during the 2020 calendar year. After the second fraudulent modification

 request was approved, Defendant Porter directed Defendant Kelly to cause more falsified federal

 tax documents for Butler Group to be filed with the IRS through her tax preparation business, The

 Finn , which she did.




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        107.    On or about Apri 1 22, 2021 , Defendant Butler caused Defendant Porter, with the

 assistance of Defendant Davis, to submit a fraudulent First Draw PPP loan application to

 third-party SBA lender First Bank of the Lake for Echelon Media. As Defendant Butler knew

 would occur, in that fraudulent loan application, Defendant Porter falsely inflated Echelon Media' s

 average monthly payroll costs, which he supported by supplying First Bank of the Lake with

 falsified federal tax documents, and further falsely represented, among other things, that all loan

 proceeds would be used only for certain business-related purposes, specifically maintaining

 payroll and making payments for rent, utilities, and operations expenses.

        108.    Acting in reliance on the truth of Defendant Butler, Defendant Porter, Defendant

 Holmon, and Defendant Davis' s false representations and fraudulent documentation, the SBA and

 third-party SBA lender First Bank of the Lake approved each of those loan applications and

 modification requests. Following the approval of those fraudulent loan applications and

 modification requests, the SBA and third-party SBA lender First Bank of the Lake electronically

 transferred a total of more than $1 million in PPP and COVID-19 EIDL loan proceeds to the

 business bank accounts of Defendant Butler' s businesses.

         109.   After fraudulently obtaining more than $1 million in PPP and COVlD-19 EIDL

 loan proceeds, Defendant Butler used her loan proceeds for unauthorized purposes, including to

 fund expenses of Gospel Music Hall of Fame, to pay more than $200,000 of preparer fees to

 Defendant Porter and Defendant Holmon, and to pay for personal expenses, such as personal

 vehicles and other personal purchases at restaurants and designer retail stores like Gucci.

         110.   Defendant Butler, with the assistance of Defendant Porter, later fraudulently

 applied for full forgiveness of the PPP loan that she fraudulentl y obtained. Had First Bank of the




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 Lake not denied that fraudulent forgiveness application, Defendant Butler would have been

 relieved of the obligation to repay that PPP loan.

                  Defendant Kelly and Defendant Sampson's Fraudulent COVID-19 Loans

          111 .     Defendant Kelly and Defendant Sampson, with the assistance of Defendant Porter,

 caused numerous fraudulent PPP and COVID-19 EIDL loan applications to be submitted to the

 SBA and a third-party SBA lender for their small business, Reign, including the following:



              5, 2021
                                                        PPP First Draw              $397,210
     November 4, 2021                                   COVTD-19 ETDL         $1 ,029,400 denied
         TOTAL                                                                     $1,576,610
                                                                               $397,210 funded

          112.      On or about January 5, 2021 , Defendant Kelly and Defendant Sampson caused

 Defendant Porter to submit a fraudulent COVTD-19 EIDL loan application to the SBA for Reign.

 With Defendant Kelly and Defendant Sampson ' s knowledge and authorization, in that fraudulent

 loan application, Defendant Porter falsely inflated Reign ' s gross profit during the 12 months prior

 to January 31 , 2020-when Reign was not even operating- and further falsely represented, among

 other things, that Defendant Sampson was the 85% owner of Reign. Defendant Porter listed

 himself in the "preparer" se9tion of the loan application so that he could communicate directly

 with the SBA regarding the application. Had the SBA not denied that fraudulent loan application,

 Defendant Kelly and Defendant Sampson would have fraudulently obtained $150,000 in

 COVID-19 EIDL loan proceeds.

          113.      On or about February 11 , 2021 , Defendant Kelly and Defendant Sampson caused

 Defendant Porter to submit a fraudulent First Draw PPP loan application to third-party SBA lender

 Itria Ventures LLC ("Itria Ventures") for Reign. With Defendant Kelly and Defendant Sampson 's



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 knowledge and authorization, in that fraudulent loan application, Defendant Porter falsely inflated

 Reign ' s average monthly payroll costs, which he supported by supplying Itria Ventures LLC with

 falsified federal tax documents, concealed that Defendant Kelly owned 20% or more of the equity

 in Reign, and further falsely represented, among other things, that Reign was in operation on

 February 15 , 2020, that Defendant Sampson was the 70% owner of Reign, and that all loan

 proceeds would be used only for certain business-related purposes, specifically maintaining

 payroll and making paymen'ts for rent and utilities.

        114.    On or about November 4, 2021, Defendant Kelly and Defendant Sampson caused

 Defendant Porter to submit another fraudulent COVID-19 EIDL loan application to the SBA for

 Reign. With Defendant Kelly and Defendant Sampson's knowledge and authorization, in that

 fraudulent loan application, Defendant Porter falsely inflated Reign's gross profit during the 2020

 calendar year, which he supported by supplying the SBA with falsified federal tax documents, and

 further falsely represented, among other things, that Defendant Kelly was the 90% owner of Reign.

 Defendant Porter listed himself in the " preparer" section of the loan application so that he could

 communicate directly with the SBA regarding the application. Before Defendant Porter submitted

 the loan application, Defendant Kelly caused falsified federal tax documents for Reign to be filed

 with the IRS through her tax preparation business, The Firm. Had the SBA not denied that

 fraudulent loan application, Defendant Kelly and Defendant Sampson would have fraudulently

 obtained more than $1 million in COVID-19 EIDL loan proceeds.

         115.   Acting in reliance on the truth of Defendant Kelly, Defendant Sampson, and

 Defendant Porter' s false representations and fraudulent documentation, third-party SBA lender

 ltria Ventures approved the fraudulent PPP loan application. Following the approval of that

 fraudulent loan application, third-party SBA lender ltria Ventures electronically transferred a total



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 of more than $300,000 in PPP loan proceeds to the business bank account of Defendant Kelly and

 Defendant Sampson ' s business, Reign.

        116.    After fraudulently obtaining more than $300,000 in PPP loan proceeds, Defendant

 Kelly and Defendant Sampson used at least half of those proceeds for unauthorized purposes,

 including by paying more than $30,000 of preparer fees to Defendant Porter and disbursing more

 than $100,000 to Defendant Sampson' s personal bank accounts.

        117.    Defendant Kelly and Defendant Sampson, with the assistance of Defendant Porter,

 later fraudulently applied for full forgiveness of the PPP loan that they fraudulently obtained. Had

 Jtria Ventures not denied that fraudulent forgiveness application, Defendant Kelly and Defendant

 Sampson would have been relieved of the obligation to repay the PPP loan.

                           Defendant Davis ' s Fraudulent COVID-19 Loan

        118.    On or about August 1, 2020, Defendant Davis caused Defendant Holmon to submit

 a fraudulent COVID-19 EIDL loan application to the SBA for her small business, Distinq ' d. As

 Defendant Davis knew would occur, in that fraudulent loan application, Defendant Holmon falsely

 inflated Distinq ' d' s gross profit during the 12 months prior to January 31 , 2020 and further falsely

 represented, among other things, that Defendant Davis ' s grandmother, rather than Defendant

 Davis, was the majority owner ofDistinq ' d. As a condition of obtaining a COVID-19 EIDL loan

 for Distinq ' d, Defendant Holmon, with Defendant Davis ' s knowledge and authorization, falsely
                                                                                            •
 represented in a loan authorization and agreement that all loan proceeds would be used solely as

 working capital to alleviate economic injury caused by the COVID-19 pandemic. Before causing

 Defendant Holmon to submit the fraudulent loan application, Defendant Davis opened a business

 bank account for Distinq ' d, for which she was the sole signatory.




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                  119.     Relying on the truth of Defendant Davis ' s false representations, the SBA approved

         that fraudulent loan application. Following the approval of that fraudulent loan application, the

         SBA electronically transferred a total of more than $95 ,000 in COVlD-19 ElDL loan proceeds to

         the business bank account of Defendant Davis' s business, Distinq ' d.

                  120.     After fraudulently obtaining more than $95 ,000 in COVID-19 EIDL loan proceeds,

         Defendant Davis used her loan proceeds for unauthorized purposes, including by at least $20,000

         of preparer fees to Defendant Holmon and paying for personal expenses, such as personal

         purchases at restaurants and designer retail stores like Louis Vuitton.

                                               The Interstate Wire Transmissions

                  121.     On or about the dates set forth below, within the Eastern District of Missouri and

         elsewhere, the defendants specified below, for the purpose of executing and attempting to execute

         the above-described scheme and artifice, transmitted, and caused to be transmitted, by means of

         wire communication in interstate commerce, certain writings, signs, signals, pictures, and sounds,

         as follows:

ri--"ft9_~nf~-· -.-;~:p~rc·~da·uts.).' Appro'iiiif~ic:oate· .··: •• :·. ··/ -. ~-·:;i:t':~wire.i>escriptfon \ ·. ": • --.--•··:·~·.\i;.;'.
        2                Porter           March 30, 2020           Electronic submission of fraudulent COVID-19 EIDL
                                                                   loan application to the SBA for Design Retail , which
                                                                   traveled through an out-of-state server from the Eastern
                                                                   District of Missouri.
        3                Porter             July 8, 2020           Electronic submission of fraudulent First Draw PPP loan
                                                                   application to Kabbage for Design Retail, which traveled
                                                                   through an out-of-state server from the Eastern District of
                                                                   Missouri.
        4                Porter             April 9, 2021          Electronic submission of fraudulent Second Draw PPP
                                                                   loan application to Amur for Design Retail, which
                                                                   traveled through an out-of-state server from the Eastern
                                                                   District of Missouri .
        5               Porter              July 15, 2020          Electronic submission of fraudulent COVlD-19 ElDL
                       Holmon                                      loan application to the SBA for Unlimited 66, which
                                                                   traveled through an out-of-state server from the Eastern
                                                                   District of Missouri.



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·' ·,1.-111111.]i-:\i'   l~/.l I Ti1 nmt t: 111 &.-i-:
                                                           ,..,.,,     '...   •.. . . .   ~.   •, · ,



                                                         '&]1]11 ■ U:•111t:1 , .. lv.~{QI ,,'6 'fJ •J£i1ii, -                  ·-~-·
                                                                                                                                  .,.   ,.,,.,..9 ~, .. 11111nu,.,   .,.,,,_,,.-~·-   "·.·?;; :~~:.;
         6                          Porter                     August 25 , 2020                                Electronic subm ission of fraudulent COVID-19 EIDL
                                  Holmon                                                                       loan application to the SBA for Hazelwood Auto, which
                                                                                                               traveled through an out-of-state server from the Eastern
                                                                                                               District of Missouri.
         7                       Porter                    September 3, 2020                                   Electronic submission of fraudulent COVID-19 EIDL
                                Holmon                                                                         loan application to the SBA for State Street, which
                                                                                                               traveled through an out-of-state server from the Eastern
                                                                                                               District of Missouri .
         8                        Porter                             April 21, 2021                            Electronic submission of fraudulent First Draw PPP loan
                                                                                                               application to Northeast Bank for State Street, which
                                                                                                               traveled through an out-of-state server from the Eastern
                                                                                                               District of Missouri.
         9                      Holmon                               April 14, 2020                            Electronic submission of fraudulent COVID-19 EIDL
                                                                                                               loan application to the SBA for Davaire Brands, which
                                                                                                               traveled through an out-of-state server from the Eastern
                                                                                                               District of Missouri.
        10                       Holmon                              June 14, 2020                             Electronic submission of fraudulent First Draw PPP loan
                                                                                                               application to Milestone Bank for Davaire Brands, which
                                                                                                               traveled through an out-of-state server from the Eastern
                                                                                                               District of Missouri.
        11                       Holmon                              June 20, 2020                             Electronic submission of fraudulent COVID-19 EIDL
                                                                                                               loan appl ication to the SBA for OMG Labs, which
                                                                                                               traveled through an out-of-state server from the Eastern
                                                                                                               District of Missouri.
        12                       Holmon                              July 15 , 2020                            Electronic submission of fraudulent COYID-19 EIDL
                                                                                                               loan application to the SBA for Mezzanine, which
                                                                                                               traveled through an out-of-state server from the Eastern
                                                                                                               District of Missouri.
        13                        Porter                             August 3, 2020                            Electronic submission of fraudulent COVID-19 EIDL
                                 Holmon                                                                        loan application to the SBA for Mad Bird, which traveled
                                                                                                               through an out-of-state server from the Eastern District of
                                                                                                               Missouri.
        14                        Porter                              July 8, 2020                             Electronic submission of fraudulent COVID-19 EIDL
                                 Holmon                                                                        loan application to the SBA for Butler Group, which
                                  Butler                                                                       traveled through an out-of-state server from the Eastern
                                                                                                               District of Missouri .
        15                         Porter                  February 10, 2022                                   Electronic submission of fraudulent COVID-19 EIDL
                                   Butler                                                                      loan modification request to the SBA for Butler Group,
                                                                                                               which traveled through an out-of-state server from the
                                                                                                               Eastern District of Missouri.
        16                         Porter                            April 19, 2022                            Electronic submission of second fraudulent COVID-19
                                   Butler                                                                      EIDL loan modification request to the SBA for Butler
                                                                                                               Group, which traveled through an out-of-state server
                                                                                                               from the Eastern District of Missouri.



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17             Porter          April 22, 2021     Electronic submission of fraudulent First Draw PPP loan
               Butler                             application to First Bank of the Lake for Echelon Media,
               Davis                              which traveled through an out-of-state server from the
                                                  Eastern District of Missouri.
18           Porter           January 5, 2021     Electronic submission of fraudulent COVID-19 EIDL
             Kelly                                loan application to the SBA for Reign, which traveled
            Sampson                               through an out-of-state server from the Eastern District of
                                                  Missouri .
19           Porter          February 11 , 2021   Electronic submission of fraudulent First Draw PPP loan
             Kelly                                application to ltria Ventures for Reign, which traveled
            Sampson                               through an out-of-state server from the Eastern District of
                                                  Missouri.
20           Porter          November 4, 2021     Electronic submission of second fraudulent COVID-19
             Kelly                                ElDL loan application to the SBA for Reign, which
            Sampson                               traveled through an out-of-state server from the Eastern
                                                  District of Missouri.
21          Holmon             August 1, 2020     Electronic submission of fraudulent COVlD-19 EIDL
             Davis                                loan application to the SBA for Distinq'd, which traveled
                                                  through an out-of-state server from the Eastern District of
                                                  Missouri .

        All in violation of Title 18, United States Code, Sections 1343 and 2.

                                          COUNTS 22-33
                        (Aggravated Identity Theft: 18 U.S.C. §§ 1028A and 2)

        122.     The above paragraphs are hereby realleged and incorporated by reference.

        123.     On or about the dates set forth below, within the Eastern District of Missouri and

 elsewhere, the defendants specified below, while being aided, abetted, counseled, encouraged, and

 induced by one another and others, known and unknown to the Grand Jury, during and in relation

 to a felony violation enumerated in 18 U.S .C. § 1028A(c), that being wire fraud in violation of 18

 U.S.C. §§ 1343 and 2, knowingly transferred, possessed, and used, without lawful authority, a

 means of identification of another person, described below for each count, knowing that the means

 of identification belonged to another actual person:




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22          Porter         March 30, 2020      Name, date of birth, and social security number of T.P.
                                               used in fraudulent Design Retail COVID- l 9 EIDL loan
                                               a lication.
23          Porter           July 8, 2020      Name and social security number of T.P. used m
                                               fraudulent Design Retail First Draw PPP loan
                                               a lication.
24          Porter          April 9, 2021      Name and social security number of T.P. used 10
                                               fraudulent Design Retail Second Draw PPP loan
                                               a lication.
25          Porter          July 15 , 2020     Name, date of birth, and social security number of R.P.
                                               used in fraudulent Unlimited 66 COVID-19 EIDL loan
                                               a lication.
26          Porter        August 25, 2020      Name, date of birth, and social security number of D.P.
                                               used in fraudulent Hazelwood Auto COVID-19 EIDL
                                               loan a lication.
27          Porter       September 3, 2020     Name, date of birth, and social security number of A.P.
                                               used in fraudulent State Street COVID-19 EIDL loan
                                               a lication.
28          Porter         April 21 , 2021     Name and social security number of A.P. used m
                                               fraudulent State Street First Draw PPP loan a lication.
29         Holmon          April 14, 2020      Name, date of birth, and social security number of I.H.
                                               used in fraudulent Davaire Brands COVID-19 EIDL loan
                                               a lication.
30         Holmon           June 14, 2020      Name and social security number of I.H. used m
                                               fraudulent Davaire Brands First Draw PPP loan
                                               a lication.
31         Holmon           July 15, 2020      Name, date of birth, and social security number of M.M.
                                               used in fraudulent Mezzanine COVID-19 EIDL loan
                                               a lication.
32         Holmon          August 3, 2020      Name, date of birth, and social security number of D.H.
            Porter                             used in fraudulent Mad Bird COVID-19 EIDL loan
                                               a lication.
33         Holmon          August 1, 2020      Name, date of birth, and social security number of H.B.
            Davis                              used in fraudulent Distinq'd COVID-19 EIDL loan
                                               a lication.

       All in violation of Title 18, United States Code, Sections 1028A and 2.




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                                                                                           COUNTS 34-47
                                                                               (Money Laundering: 18 U.S.C. §§ 1957 and 2)

                                    124.                  The above paragraphs are hereby realleged and incorporated by reference.

                                    125.                  On or about the dates set forth below, within the Eastern District of Missouri and

                      elsewhere, the defendants specified below, while being aided, abetted, counseled, encouraged, and

                       induced by one another and others, known and unknown to the Grand Jury, knowingly engaged

                      and attempted to engage in 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 issuance of checks drawn on federally insured financial institutions, such property having

                      been derived from a specified unlawful activity, that is, wire fraud , in violation of Title 18, United

                      States Code, Section 1343 , as follows:
ffll{'::"/l"!Gl";~'V,,.-~,._,r   1.~S"-,, ..... \'11,I:---.   O"~•~s,-~.   ~~-...--,""°t""C..N::"'   ✓ •'?r,-'<;("..,"'   1-.:1-·-.:~,..   ~r•~.-   ,.,.   -   •   ,-~   ~l"'ff:''N:f""   I(   7r,r1Y'<-c    . . . . . . . . . . . -~.··   ,

:,'i'::Ih,(:ount ·, • ·:. 1 D~f~11dJnts ; ~ Approxiq1li'tt~D~lte ;     ·, '. -.".'.\ii"'_::/ , .'·•',Jransa_ction . - ~~' ~: ·.,\~- , ~ 'p :,~~~,
            34                Porter           July 28, 2020       Check No. 5051 in the amount of $15,000 drawn on
                                                                   Design Retail ' s Bank of America account **2963
                                                                   payable to Jon Fuhrer & Company for a loan secured by
                                                                   Defendant Porter's personal residence.
            35                Porter        September 29, 2020 PNC Bank Cashier's Check No. 334224 in the amount
                                                                   of $22,000 fund ed by withdrawal from Hazelwood
                                                                   Auto 's PNC Bank account **3761 payable to Design
                                                                   Retail.
            36                Porter        September 30, 2020 US Bank Cashier's Check No. 6960514718 in the
                                                                   amount of $25 ,200 funded by withdrawal from
                                                                   Unlimited 66 's US Bank account **2987 payable to
                                                                   Design Retail.
            37                Porter        September 30, 2020 Triad Bank Cashier's Check No. 009143 in the amount
                                                                   of $27,250 funded by withdrawal from State Street's
                                                                   Triad Bank account **9718 payable to Design Retail.
            38               Holmon           April 11 , 2022      US Bank Cashier's Check No. 8407521365 in the
                                                                   amount of $359,100 funded by withdrawal from
                                                                   Mezzanine's US Bank account **2979 payable to Mad
                                                                   Bird.
            39               Holmon         November   29, 2022    Commerce Bank Cashier's Check No. 0081333587 in
                                                                   the amount of $98,000 funded by withdrawal from Mad
                                                                   Bird 's Commerce Bank account **1244 payabl e to
                                                                   Porsche St. Louis for the purchase of a 2020 Aston
                                                                   Martin Vantage.


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                                                   Enterprise Bank & Trust Cashier' s Check No. 441074 in
                                                   the amount of $19,000 funded by withdrawal from
                                                   Butler Group' s Enterprise Bank & Trust account **0160
                                                    a able to Davaire Brands.
41            Butler        September 2, 2020      Enterprise Bank & Trust Cashier' s Check No. 441204 in
                                                   the amount of $29,800 funded by withdrawal from
                                                   Butler Group ' s Enterprise Bank & Trust account **0160
                                                     a able to Davaire Brands.
42            Butler          April 22, 2021       Check No. 5201 in the amount of $79,844.70 drawn on
                                                   Echelon Media' s Simmons Bank account **7182
                                                     a able to Desi n Retail for "e ui ment."
43            Butler          April 27, 2021       Simmons Bank Cashier's Check No. 202240225 in the
                                                   amount of $60,000 funded by withdrawal from Echelon
                                                   Media ' s Simmons Bank account **7182 payable to
                                                   Butler Grou .
44            Butler          March 16, 2022       Check No. 1080 in the amount of $30,000 drawn on
                                                   Butler Group ' s Enterprise Bank & Trust account **0160
                                                    a able to Gos el Music Hall of Fame for a "donation."
45            Butler          March 26, 2022       Check No. 1091 in the amount of $35 ,000 drawn on
                                                   Butler Group ' s Enterprise Bank & Trust account **0160
                                                     a able to Desi n Retail for "services."
46            Butler          April 27, 2022       Enterprise Bank & Trust Cashier's Check No. 473724 in
                                                   the amount of $70,000 funded by withdrawal from
                                                   Butler Group's Enterprise Bank & Trust **0160 payable
                                                   to Desi n Retail.
47            Kelly          February 22, 2021     Check No. 1064 in the amount of $39,721 drawn on
             Sampson                               Reign's Bank of America account **7025 payable to
                                                   Design Retail (under the d/b/a Heartland POS) for "POS
                                                   E ui ment."

 All in violation of Title 18, United States Code, Sections 1957 and 2.

                                  FORFEITURE ALLEGATION

        The Grand Jury further alleges there is probable cause that:

        1.      Pursuant to Title 18, United States Code, Section 98l(a)(l)(C) and Title 28, United

 States Code, Section 2461 , upon conviction of an offense in violation of Title 18, United States

 Code, Section 1343 and Section 1349, as set forth in Counts 1 through 21 above, the defendant(s)

 shall forfeit to the United States of America any property, real or personal , which constitutes or is

 derived from proceeds traceable to such violation(s). Subject to forfeiture is a sum of money equal


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 to the total value of any property, real or personal , which constitutes or is derived from proceeds

 traceable to such violation(s).

        2.       Pursuant to Title 18, United States Code, Section 982(a)(l ), upon conviction of an

 offense in violation of Title 18, United States Code, Section 1957, as set forth in Counts 34 through

 47 above, the defendant(s) shall forfeit to the United States of America any property, real or

 personal , involved in such offense, or any property traceable to such property. Subject to forfeiture

 is a sum of money equal to the total value of any property, real or personal , involved in such

 offense, or any property traceable to such property

         3.      Specific property subject to forfeiture includes, but is not limited to, the following:

                 a.     7801 Olive Boulevard, St. Louis, Missouri 63130;

                 b.     7805 Olive Boulevard, St. Louis, Missouri, 63130;

                 c.     9691 Huron Drive, St. Lou is, Missouri 63132;

                 d.      5623 Bartmer Avenue, St. Louis, Missouri 63112;

                 e.     2020 Aston Martin Vantage, VIN: SCFSMGAW4LGN03732;

                 f.     2019 Mercedes Sprinter Van, VIN: WDZPF0CD0KPl 18510; and

                 g.      2021 Cadillac Escalade, VIN: 1GYS4MKL2MR195431.

         4.      If any of the property described above, as a result of any act or om ission of the

 defendant(s):

                 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




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                e.      has been commingled with other property which cannot be divided without

                       difficulty,

 the United States of America will be entitled to the forfeiture of substitute property pursuant to

 Title 21 , United States Code, Section 853(p).

                                                             A TRUE BILL.


                                                             FOREPERSON

 THOMAS C. ALBUS
 United States Attorney


 JUSTIN M. LADENDORF #68558MO
 Assistant United States Attorney




                                                  41
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