Indictment — United States v. Dalton Haas, Northern District of West Virginia (Document 1)
Summary
A grand jury Indictment in United States v. Dalton Haas, Case 5:22-cr-00051-JPB-JPM, in the United States District Court for the Northern District of West Virginia, filed December 6, 2022. Counts One through Seven charge wire fraud under 18 U.S.C. § 1343, alleging that from in or about March 2020 until in or about January 2021 Haas submitted EIDL applications and $10,000 advance requests for businesses he purportedly owned, including the Lebanese Restuarant (sic) and Bakery, West Virginia Hockey League, Wheeling Wine Festival and Wheeling Hockey Association. Counts Eight through Twelve charge false statements to the SBA under 15 U.S.C. § 645(a) about revenues, cost of goods and employees. The indictment alleges, for example, that the restaurant application claimed $22,000 in gross revenue and 25 employees when the business was not in operation. It ends with a forfeiture allegation.
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“Indictment — United States v. Dalton Haas, Northern District of West Virginia (Document 1).”
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Case 5:22-cr-00051-JPB-JPM Document 1 Filed 12/06/22 Page 1 of 8 PageID #: 1
UNITED STATES DISTRICT COURT FOR THE
NORTHERN DISTRICT OF WEST VIRGINIA ED
DEC 6 2022
U.S. DISTRICT COURT~WVND
UNITED STATES OF AMERICA, WHEELING, WV 26003
Criminal No. 5:22-CR-s
v. Violations: 15 U.S.C. § 645(a)
18 U.S.C. § 1343
DALTON HAAS,
Defendant.
INDICTMENT
The Grand Jury charges that:
INTRODUCTION
At all times relevant to this Indictment:
The COVID-19 Pandemic and the CARES Act
1. The Coronavirus Aid, Relief, and Economic Security (“CARES”) Act was a federal law
enacted in or about March 2020, designed to provide emergency financial assistance to the millions who
were suffering the economic effects caused by the C OVID- 19 pandemic.
2. Among other relief efforts, the United States sought to provide financial support to
eligible businesses that could be used to offset certain business expenses.
3. The Small Business Administration (“SBA”) is an executive branch agency of the United
States government that provided support to entrepreneurs and small businesses. The SBA is
headquartered in Washington, DC and maintained its computer servers outside of the State of West
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Virginia. The SBA’s mission was to maintain and strengthen the nation’s economy by enabling the
establishment and viability of small businesses and by assisting in the economic recovery of communities
after disasters.
4. As part of this effort, the SBA enabled and provided for loans that came directly from the
U.S. Government.
Economic Injury Disaster Loans
5. One source of relief provided by the CARES Act was the authorization for the SBA to
provide Economic Injury Disaster Loans (“EIDL”) to eligible small businesses experiencing substantial
financial disruption due to the COVID-19 pandemic.
6. In order to obtain an EIDL, a qualifying business had to submit an online application to
the SBA and provide information about its operations, including the number of employees, gross
revenues for the twelve-month period preceding the disaster (identified as January 31, 2020), and the
cost of goods the business sold in the twelve-month period preceding the disaster. The applicant also
had to certify that all the information in the application was true and correct to the best of the applicant’s
knowledge.
7. In addition, the CARES Act authorized the SBA to issue advances of up to $10,000 to
small businesses applying for an EIDL (“EIDL Advance”). The amount of the EIDL Advance was
determined by the number of employees claimed by the applicant, with an advance of $1,000 for each
employee up to $10,000.
8. EIDL applications were submitted directly to the SBA online at
https://covidl9relief.sba.gov/#/ and processed by the agency with support from a government contractor,
Rapid Finance. The amount of each loan was based in part, on the information provided by the applicant
about the number of employees, operating expenses for the twelve months prior to the date ofthe disaster,
gross revenue for the twelve months prior to the disaster, and the cost of goods sold for the twelve months
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prior to the date of the disaster. Any funds issued under EIDL were issued directly by the SBA.
9. EIDL funds could be used for payroll expenses, sick leave, production costs, and business
obligations, such as debts, rent, and mortgage payments.
COUNTS ONE THROUGH SEVEN
(Wire Fraud)
10. The Grand Jury re-alleges and incorporates by reference the factual allegations contained
in paragraphs 1 through 9 of this indictment as if fully set forth herein.
11. Beginning in or about March 2020 and continuing until in or about January 2021,
defendant DALTON HAAS devised and conducted a scheme to defraud the United States by submitting
fraudulent EIDL applications with EIDL Advance requests to the SBA containing false representations.
12. It was part of the scheme that DALTON HAAS submitted EIDL applications and
requests for EIDL Advances in the names of various businesses he purportedly owned. All of the
applications submitted by DALTON HAAS included false representations designed to fraudulently
obtain proceeds from the SBA.
13. It was a further part of the scheme that the DALTON HAAS would misrepresent and
conceal material facts regarding the businesses or organizations for which he submitted applications
EIDL Loans and Advances. In particular, DALTON HAAS, materially misrepresented the number of
employees of the business, the gross revenue of the business in the twelve months preceding the disaster
caused by the COVID pandemic, and the cost of business goods sold in the twelve months preceding the
COVID pandemic.
14. It was further part of the scheme that DALTON HAAS reported to own a sole
proprietorship called the Lebanese Restuarant (sic) and Bakery that he purportedly established in
November 2019.
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15. It was further part of the scheme that DALTON HAAS reported to own a C-type non
profit corporation established in 2018 called the “West Virginia Hockey League.” West Virginia
Secretary of State records show the corporation was established on April 15, 2020.
16. It was further part of the scheme that DALTON HAAS reported to be the sole proprietor
of the “Wheeling Wine Festival” which he claimed to establish in January 2019.
17. It was part of the scheme that DALTON HAAS reported to own a non-profit limited
liability company he established in June 2019 called “Wheeling Hockey Association.” West Virginia
Secretary of State records reflect that the limited liability company voluntary association became
effective April 20, 2020.
18. On or about the dates specified as to each count below, for the purpose of executing, and
attempting to execute, the scheme to defraud, in Wheeling, in Ohio County, in the Northern District of
West Virginia, DALTON HAAS did knowingly transmit or cause to be transmitted by means of a wire
communication in interstate commerce the following writings, signs, signals, pictures, and sounds:
Count Date Description
1 March 30, 2020 An internet transmission originating from West Virginia to the SBA
server in Iowa constituting a false and fraudulent EIDL application for
a loan and a request for an advance of $10,000 in the name of
“Lebanese Restuarant (sic) and Bakery”.
2 March 30, 2020 An internet transmission originating from West Virginia to the SBA
server in Iowa constituting a false and fraudulent EIDL application for
a loan and a request for an advance of $10,000 in the name of “West
Virginia Hockey League”.
3 April 13 2020 A wire transfer originating from Colorado to Virginia to Main Street
Bank in West Virginia constituting a fraudulently obtained EIDL
advance of $10,000 for the “Lebanese Restuarant (sic) and Bakery”
deposited in Dalton Haas’ Main Street Bank Account ending 0338.
4 April 21, 2020 A wire transfer originating from Colorado to Virginia to Main Street
Bank in West Virginia constituting a fraudulently obtained EIDL
advance of $10,000 for the “West Virginia Hockey League” deposited
in Dalton Haas’ Main Street Bank Account ending in 0181.
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5 March 30, 2020 An internet transmission originating from West Virginia to the SBA
server in Iowa constituting a false and fraudulent EIDL application for
~ a loan and a request for an advance of $10,000 in the name of
“Wheeling Wine Festival”.
6 July 7, 2020 An internet transmission originating from West Virginia to the SBA
server in Iowa constituting a false and fraudulent EIDL application for
a loan and a request for an advance of $10,000 in the name of
“Wheeling Hockey Association”.
7 January 2, 2021 An internet transmission originating from West Virginia to the SBA
server in Iowa constituting a false and fraudulent EIDL application for
a loan and a request for an advance of $10,000 in the name of
“Wheeling Wine Festival”.
In violation of Title 18, United States Code, Section 1343.
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COUNTS EIGHT THROUGH TWELVE.
(False Statement to the SBA)
19. The Grand Jury re-alleges and incorporates by reference the factual allegations contained
in paragraphs 1 through 9 of this Indictment as if fully set forth herein.
20. On or about the dates specified as to each count below, in Wheeling, Ohio County, West
Virginia, within the Northern District of West Virginia, the defendant DALTON HAAS did knowingly
and intentionally make a false statement to the SBA for the purpose of influencing in any way, the actions
of the SBA.
Count Date Description
8 March 30, 2020 False statement to the SBA that the “Lebanese Restuarant (sic) and
Bakery” was established in November 2019, that it had $22,000 gross
revenue in the twelve months prior to the pandemic, $8,000 was the
cost of goods sold in the previous 12 months and that there were 25
employees when he knew the business was not in operation.
9 March 30, 2020 False statement to the SBA that “West Virginia Hockey League” had
gross revenues of $40,000 in a twelve-month period prior to the
pandemic, that the costs of operation in the twelve months prior was
$50,000 and that ten people were employed by West Virginia Hockey
League when he knew the West Virginia Hockey League did not have
the gross revenues, costs of operation or employees reported.
10 March 30, 2020 False statements to the SBA that the “Wheeling Wine Festival’s”
gross revenue in the twelve months prior to the pandemic was
$85,000, that the costs of good in the previous twelve months was
$12,000 and that the Wheeling Wine Festival employed 20 individuals
when he knew that the Wheeling Wine Festival did not have the gross
revenue, costs of goods or number of employees reported.
11 July 7, 2020 False statements to the SBA that in the twelve months prior to the
pandemic, “Wheeling Hockey Association’s” costs of goods sold was
$13,000, that the gross revenues was $35,000, and that it employed 15
people when he knew that the Wheeling Hockey Association did not
have the gross revenue, cost of goods or number of employees
reported.
12 January 2, 2021 False statement to the SBA that the “Wheeling Wine Festival” had
gross revenues of $95,000 in the twelve months prior to the pandemic,
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the cost of goods sold in the twelve months prior the pandemic was
$5,000 and that the Wheeling Wine Festival employed ten individuals
when he knew that the Wheeling Wine Festival did not have the gross
________________ revenue, cost of goods or number of employees reported.
In violation of Title 15, United States Code, Section 645(a).
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FORFEITURE ALLEGATION
Wire Fraud
1. Pursuant to Title 28, United States Code, Sections 2461(c), Title 18 United States Code,
Sections 981(a)(1)(C), 1956(c)(7)(A), and 1961(1) and Title 21, United States Code, Section 853, the
government will seek the forfeiture of property as part of the sentence imposed in this case, that is, the
forfeiture of any property, real or personal, which constitutes or is derived from proceeds traceable to a
violation of Title 18, United States Code, Section 1343, or a conspiracy to violate such offense, including
a money judgment in the amount of at least $20,000.
2. Pursuant to Title 28, United States Code, Section 2461(c), the government will seek
forfeiture of substitute property up to the value of property subject to direct forfeiture that is not available
for forfeiture on account of any act or omission contemplated by Title 21, United States Code, Section
853(p)(l).
A true bill,
/5/
Foreperson
/5/
WILLIAM IHLENFELD
United States Attorney
Jennifer T. Conklin
Assistant U.S. Attorney
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