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.
Case: 4:26-cr-00174-MTS-JMB Doc. #: 2 Filed: 04/15/26 Page: 2 of 41 PageID
#: 52
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.
2
#
Case: 4:26-cr-00174-MTS-JMB Doc. #: 2 Filed: 04/15/26 Page: 3 of 41 PageID
#: 53
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.
3
#
Case: 4:26-cr-00174-MTS-JMB Doc. #: 2 Filed: 04/15/26 Page: 4 of 41 PageID
#: 54
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.
4
#
Case: 4:26-cr-00174-MTS-JMB Doc. #: 2 Filed: 04/15/26 Page: 5 of 41 PageID
#: 55
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.
5
#
Case: 4:26-cr-00174-MTS-JMB Doc. #: 2 Filed: 04/15/26 Page: 6 of 41 PageID
#: 56
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.
6
#
Case: 4:26-cr-00174-MTS-JMB Doc. #: 2 Filed: 04/15/26 Page: 7 of 41 PageID
#: 57
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.
7
#
Case: 4:26-cr-00174-MTS-JMB Doc. #: 2 Filed: 04/15/26 Page: 8 of 41 PageID
#: 58
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
8
#
Case: 4:26-cr-00174-MTS-JMB Doc. #: 2 Filed: 04/15/26 Page: 9 of 41 PageID
#: 59
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.
9
#
Case: 4:26-cr-00174-MTS-JMB Doc. #: 2 Filed: 04/15/26 Page: 10 of 41 PageID
#: 60
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
#
Case: 4:26-cr-00174-MTS-JMB Doc. #: 2 Filed: 04/15/26 Page: 11 of 41 PageID
#: 61
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.
11
#
Case: 4:26-cr-00174-MTS-JMB Doc. #: 2 Filed: 04/15/26 Page: 12 of 41 PageID
#: 62
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
12
#
Case: 4:26-cr-00174-MTS-JMB Doc. #: 2 Filed: 04/15/26 Page: 13 of 41 PageID
#: 63
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.
13
#
Case: 4:26-cr-00174-MTS-JMB Doc. #: 2 Filed: 04/15/26 Page: 14 of 41 PageID
#: 64
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
14
#
Case: 4:26-cr-00174-MTS-JMB Doc. #: 2 Filed: 04/15/26 Page: 15 of 41 PageID
#: 65
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
15
#
Case: 4:26-cr-00174-MTS-JMB Doc. #: 2 Filed: 04/15/26 Page: 16 of 41 PageID
#: 66
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
16
Case: 4:26-cr-00174-MTS-JMB Doc. #: 2 Filed: 04/15/26 Page: 17 of 41 PageID
#: 67
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
17
#
Case: 4:26-cr-00174-MTS-JMB Doc. #: 2 Filed: 04/15/26 Page: 18 of 41 PageID
#: 68
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
18
#
Case: 4:26-cr-00174-MTS-JMB Doc. #: 2 Filed: 04/15/26 Page: 19 of 41 PageID
#: 69
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
19
#
Case: 4:26-cr-00174-MTS-JMB Doc. #: 2 Filed: 04/15/26 Page: 20 of 41 PageID
#: 70
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
20
#
Case: 4:26-cr-00174-MTS-JMB Doc. #: 2 Filed: 04/15/26 Page: 21 of 41 PageID
#: 71
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.
21
#
Case: 4:26-cr-00174-MTS-JMB Doc. #: 2 Filed: 04/15/26 Page: 22 of 41 PageID
#: 72
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
22
#
Case: 4:26-cr-00174-MTS-JMB Doc. #: 2 Filed: 04/15/26 Page: 23 of 41 PageID
#: 73
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
23
#
Case: 4:26-cr-00174-MTS-JMB Doc. #: 2 Filed: 04/15/26 Page: 24 of 41 PageID
#: 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 :
24
#
Case: 4:26-cr-00174-MTS-JMB Doc. #: 2 Filed: 04/15/26 Page: 25 of 41 PageID
#: 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
25
#
Case: 4:26-cr-00174-MTS-JMB Doc. #: 2 Filed: 04/15/26 Page: 26 of 41 PageID
#: 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
26
#
Case: 4:26-cr-00174-MTS-JMB Doc. #: 2 Filed: 04/15/26 Page: 27 of 41 PageID
#: 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
27
#
Case: 4:26-cr-00174-MTS-JMB Doc. #: 2 Filed: 04/15/26 Page: 28 of 41 PageID
#: 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
1
~
}; • "
·••,"£., • .
~. • ,.\
.-11:
...~~~ '½'11:,#'!-1' .... .t\
":' !!'
.Z.'•·1,),.
• '
*
"' •}r,
,,,,,,,, ,
, . , , ,•
~
•· ~ ,. ,.
ilA?k"',..:1
:
-,
rt\o(«fl"."}::f~:. ',,_,,~ ~.
!
f
i. '
s
"' I
,,.,,
,:.--,;i._".4;~, "t..Y~ci.t
· ·~~l" ·~
....- ~
,,
' ,
"'
, ,;
·~·':.,A!)-'~:
, ;
~it
(IncludmgAdvances)
'
-~-
• • ~~ ~\~
~i
~-·
~ ~~ ,,.1
- •
• '
...
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,
28
#
Case: 4:26-cr-00174-MTS-JMB Doc. #: 2 Filed: 04/15/26 Page: 29 of 41 PageID
#: 79
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.
29
#
Case: 4:26-cr-00174-MTS-JMB Doc. #: 2 Filed: 04/15/26 Page: 30 of 41 PageID
#: 80
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
30
#
Case: 4:26-cr-00174-MTS-JMB Doc. #: 2 Filed: 04/15/26 Page: 31 of 41 PageID
#: 81
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
31
#
Case: 4:26-cr-00174-MTS-JMB Doc. #: 2 Filed: 04/15/26 Page: 32 of 41 PageID
#: 82
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
32
#
Case: 4:26-cr-00174-MTS-JMB Doc. #: 2 Filed: 04/15/26 Page: 33 of 41 PageID
#: 83
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.
33
#
Case: 4:26-cr-00174-MTS-JMB Doc. #: 2 Filed: 04/15/26 Page: 34 of 41 PageID
#: 84
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.
34
#
Case: 4:26-cr-00174-MTS-JMB Doc. #: 2 Filed: 04/15/26 Page: 35 of 41 PageID
#: 85
·' ·,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.
35
#
Case: 4:26-cr-00174-MTS-JMB Doc. #: 2 Filed: 04/15/26 Page: 36 of 41 PageID
#: 86
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:
36
#
Case: 4:26-cr-00174-MTS-JMB Doc. #: 2 Filed: 04/15/26 Page: 37 of 41 PageID
#: 87
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.
37
#
Case: 4:26-cr-00174-MTS-JMB Doc. #: 2 Filed: 04/15/26 Page: 38 of 41 PageID
#: 88
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.
38
#
Case: 4:26-cr-00174-MTS-JMB Doc. #: 2 Filed: 04/15/26 Page: 39 of 41 PageID
#: 89
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
39
#
Case: 4:26-cr-00174-MTS-JMB Doc. #: 2 Filed: 04/15/26 Page: 40 of 41 PageID
#: 90
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
40
#
Case: 4:26-cr-00174-MTS-JMB Doc. #: 2 Filed: 04/15/26 Page: 41 of 41 PageID
#: 91
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
#
File and source
- File
- 2.pdf
- Size
- 682,984 bytes
- SHA-256
- 918aded635dd0c9c2c5b3a0089d0403204d97416563c5191a5af9c00da194d42
- Our copy
- 2.pdf
- Original
- No public link identified.