Indictment — No. 5:24-cr-00156 (Dkt. 1, E.D.N.C.)

Summary

Indictment filed May 7, 2024 in the Eastern District of North Carolina, case 5:24-cr-00156, against Darnell William King. The grand jury charges that King made and sold fake identity documents and access devices, used stolen identities to defraud private lenders and joined in defrauding COVID-19 relief programs, including the Paycheck Protection Program. It also charges him as a felon in possession of a firearm. The government seeks a money judgment of at least $633,396 and a CZ Scorpion Evo 9mm pistol seized on October 20, 2022. 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

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“Indictment — No. 5:24-cr-00156 (Dkt. 1, E.D.N.C.).” Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/indictment-no-5-24-cr-00156-dkt-1-e-d-n-c-6b9be28dc5/, SHA-256 7572f2aa3719fa347c6a9c4827bbbb496fbea08af215da6240681343238a296f.

Full text

FILED IN OPEN: ~
ON 5/1/2CJt
Peter A. Moore, Jr., Clerk
US District Court
Eastern District of NC

DGB
UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF NORTH CAROLINA
WESTERN DIVISION

UNITED STATES OF AMERICA )
)
V. ) INDICTMENT
)
DARNELL WILLIAM KING )

The Grand Jury charges the following:

INTRODUCTORY ALLEGATIONS

1. The Defendant, DARNELL WILLIAM KING (or "KING''), generated

and trafficked in fraudulent identity documents and access devices, which he either

sold for the purpose of executing fraud schemes, or which he used directly to engage

in fraud schemes, conspiring with others to do so . KING and other members of the

conspiracy then used the fraudulent documents and stolen identities to engage in a

series of schemes and artifices to defraud private lenders in the Eastern District of

North Carolina.

2. KING, and others known and unknown to the Grand Jury, also

conspired to defraud- and did defraud- the United States Government. This

scheme involved frauds upon institutions and agencies engaged to provide financial

assistance to the public arising from the COVID-19 pandemic.

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3. Finally, KING illegally possessed a firearm that had traveled in

interstate and foreign commerce even though he knew that he had previously been

convicted of a felony offense punishable by more than one year of imprisonment.

4. At all times relevant to this Indictment, KING was a resident of the

Eastern District of North Carolina.

I. THE PAYCHECK PROTECTION PROGRAM (PPP) LOAN
SCHEME AND ARTIFICE TO DEFRAUD

5. In March 2020, Congress passed the Coronavirus Aid, Relief, and

Economic Security (CARES) Act, which was designed to provide emergency

financial assistance to millions of Americans who were suffering from the economic

effects caused by the COVID-19 pandemic.

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

executive-branch agency of the United States government that provided support to

entrepreneurs and small businesses. The mission of the SBA was to maintain and

strengthen the nation's economy by enabling the establishment and viability of

small business and by assisting in the economic recovery of communities after

disasters.

7. Also in March 2020, the President declared an emergency under

Section 501(b) of the Robert T. Stafford Disaster Relief and Emergency Assistance

Act (42 U.S.C. §§ 5121 et seq.) in response to the COVID-19 pandemic. Many forms

of assistance made available pursuant to a Stafford Act declaration are funded

through the Disaster Relief Fund (DRF), which is the primary source of funding for

Case 5:24-cr-00156-M-KS Document 1 Filed 05/07/24 Page 2 of 19
the federal government's domestic general disaster relief programs. The CARES

Act included $45 billion in appropriations for the DRF.

8. Another source of relief provided by the CARES Act was the

authorization of up to $349 billion in forgivable loans to small businesses for job

retention and certain other expenses, through a program referred to as the

Paycheck Protection Program (PPP). In or around April 2020, Congress authorized

over $300 billion in additional PPP funding.

9. To obtain a PPP loan, businesse s were required to submit a PPP loan

application, signed by an authorized representative of the business, acknowledging

the program rules. The business was required to state (a) its average monthly

payroll expenses, or in the case of sole proprietorship , its gross income; and, if

applicable (b) the number of employees and to provide documentation showing their

payroll expenses. These figures were used to calculate the amount of money the

small business or sole proprietorship was eligible to receive under the PPP.

10. A PPP loan application was required to be processed by a participating

financial institution ("Lender"). Many Lenders constituted financial institutions, as

that term is defined in Title 18, United States Code, Section 20. If a PPP loan

application was approved, the Lender funded the PPP loan using its own moneys,

which were 100% guaranteed by the SBA. Data from the application, including

information about the borrower, the total amount of the loan, and the listed number

of employees, were transmitted by the Lender to the SBA in the course of processing

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the loan.

11. PPP loan proceeds were required to be used by businesses on certain

permissible expenses: payroll costs, interest on mortgages, rent, and utilities. In

the case of a sole proprietorship , permissible expenses were general business

expenses and owner compensation. Loans provided through the PPP had

government-backed guarantees and were 100% forgivable if the borrower submitted

documentation to the PPP lender and SBA certifying that the borrower complied

with all PPP requirements and rules.

12. Beginning at least as early as in or about March 2021 through in or

about November 2021, the Defendant, KING, conspired with L.J., L.B ., and others

to engage in fraud upon the PPP program. L.J. was a purported business owner

who engaged in a variety of frauds, often with KING, including upon the PPP

program. L.B. was an associate of L.J . who assisted in the commission of the PPP

fraud scheme.

13. One PPP loan qualification was that the applicant was an independent

contractor, sole proprietor, or other qualifying business classification with self-

employment income. Further, the applicant must have been previously self-

employed or in operation as a sole proprietorship as of February 15, 2020. KING

did not meet these eligibility requirements because in reality, KING had little or no

legitimate self-employment income in 2020. Therefore , in order to fraudulently

apply for a PPP loan, KING falsely represented that he had been earning

Case 5:24-cr-00156-M-KS Document 1 Filed 05/07/24 Page 4 of 19
substantial income prior to the COVID-19 pandemic as a driver for Uber

Technologies, Inc. ("Uber").

14. In furtherance of the fraudulent application, KING, L.J. , or L.B.

generated a forged bank statement and a false Schedule C 1 for 2020 reporting

fictitious gross earnings of $78,100 as an Uber driver. In reality, D.K. had neve r

driven for Uber or earned any such income.

15. The fraudulent PPP application was electronically submitted by L.J. or

another member of the conspiracy acting on KING's behalf, and received through

SBA servers located in Virginia and Oregon, using the fraudulent information

described above, by electronically transmitting the information to the Lender,

Benworth Capital Partners, LLC, which was headquartered in Florida and Puerto

Rico , via interstate wire transmission.

16. Benworth Capital Partners, LLC, was a "mortgage lending business"

as that term is defined in Title 18, United States Code, Section 27. Thus, Benworth

Capital Partners, LLC, was a "financial institution" as that term is defined in Title

18, United States Code, Section 20(10).

17. On or about May 10, 2021, KING received $16,270 of fraudulent PPP

proceeds, which were deposited via interstate wire transfer into KING's Navy

Federal Credit Union bank account ending in -2713. In exchange for their

assistance in obtaining COVID-19 loans, after receiving the fraudulent PPP

1A "Schedule C" is formally known as "Schedule C (IRS Form 1040), Profit or Loss
from a Business (Sole Proprietorship)."

Case 5:24-cr-00156-M-KS Document 1 Filed 05/07/24 Page 5 of 19
proceeds, KING sent L.J. $2,500 by electronic transfer.

II. THE IDENTITY THEFT SCHEME AND ARTIFICE TO DEFRAUD

18. Companies known as Credit Reporting Agencies (CRAs) are in the

business of assembling and evaluating consumer credit information for the purpose

of providing reports about the credit-worthiness of consumers to third parties.

These reports are commonly known as "credit reports." CRAs include such

companies as Equifax, Experian, and Transunion.

19. CRAs sell credit reports to businesses to assist those businesses in

making decisions concerning whether, and on what terms, to do business with the

potential customer that is the subject of a particular credit report.

20. Credit reports typically contain a credit score, which is derived from a

statistical calculation that quantifies the credit risk posed by a prospective

customer, who is identified by such factors as the customer's name and Social

Security Number. The credit score of a particular customer is influenced by many

factors, including the consumer's payment history, utilization of credit, balances,

available credit limit, and length of credit history.

21. Credit reports are derived from information provided to CRAs by

entities that, during the course of their business, acquire information concerning

the credit and payment histories of their customers, who are identified by, among

other things, their name and Credit Profile Number (CPN). CRAs utilize the

consumer's Social Security Number as the consumer's CPN.

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22. Lines of credit, or credit accounts, are the most common item

appearing on credit reports. CRAs commonly refer to these as "tradelines." The

existence of tradelines, and the timeliness of payments on tradelines, which are

linked to a specific individual through their Social Security Number, can impact the

ultimate credit score of an individual.

23. Beginning at least as early as in or about December 2021, through in

or about February 2022, the Defendant, DARNELL WILLIAM KING, conspired

with L.J and others to use personally identifiable information (PII)-such as Social

Security Numbers (CPNs), dates of birth, and other means of identification-

associated with unknowing victims for the purpose of submitting false and

fraudulent loan and credit applications to various private lenders.

24. To effectuate this scheme, L.J. or KING would first identify a CPN

associated with "good" credit, meaning that the individual associated with the CPN

had a high enough credit score that a fraudulent loan submitted using their identity

would likely be approved.

25. Then, L.J. or KING would submit a loan application for a personal line

of credit in amounts ranging from approximately $5,000 to $10,000 using a false

identity and various PII, including the CPN. These applications were submitted

online via the Internet to the lenders, who either used data servers located outside

of North Carolina or partnered with CRAs outside of North Carolina to process the

applications. Most of the lenders were also headquartered outside of North

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Carolina.

26. L.J. or KING would create an email address purporting to be

associated with the identity of the applicant, which they would use as purported

contact information in connection with the applications and to communicate with

the lender. The internet service providers associated with those email addresses

maintained servers outside of North Carolina.

27. KING or L.J. would then recruit another individual (known as a

"Mule") to physically obtain the funds from the lender. Usually, L.J. would send a

photo of the Mule to KING. KING then would create fraudulent identity

documents, including a driver's license or other purported government

identification, displaying the stolen or fictitious PII along with a true photo of the

Mule.

28. Equipped with the false identity documents created by KING , the

Mule would physically sign the application or other paperwork promising to repay

the loan purporting to be the true applicant. The Mule would then bring the

fraudulent proceeds to KING or L.J. who compensated the Mule in amounts ranging

from approximately $100 to $2,000 per transaction. Sometimes, L.J . and KING

would repeat the fraud with the same Mule and stolen identity to obtain additional

loans from other banks and lenders.

29. KING and L.J. never repaid any of these fraudulent loans.

Case 5:24-cr-00156-M-KS Document 1 Filed 05/07/24 Page 8 of 19
COUNT ONE

30. Introductory paragraphs 5 through 17 are realleged and incorporated

into this Count as factual allegations by reference as if fully set forth herein.

31. From in or about March 2021 through in or about November 2021, in

the Eastern District of North Carolina and elsewhere, Defendant DARNELL

WILLIAM KING did knowingly combine , conspire, confederate, agree, and have a

tacit understanding with L.J., L.B., and others known and unknown to the Grand

Jury, to commit offenses against the United States, specifically:

a. Wire Fraud, that is, to knowingly devise and intend to devise a

scheme and artifice to defraud the SBA and Benworth Capital

Partners, LLC., and to obtain money and property by means of

materially false and fraudulent pretenses, representations, and

promises; and for the purpose of executing the scheme, caused to be

transmitted by means of wire communication in interstate

commerce any writings, signals, signs pictures, and sounds, m

violation of Title 18, United States Code, Section 1343; and

b. Bank Fraud, that is to execute and attempt to execute a scheme or

artifice to defraud Benworth Capital Partners, LLC-a financial

institution as that term is defined in Title 18, United States Code,

Section 20-by obtaining any of the moneys, funds, credits, assets,

or securities owned by, or under the custody or control of Benworth

Case 5:24-cr-00156-M-KS Document 1 Filed 05/07/24 Page 9 of 19
Capital Partners, LLC, by means of false and fraudulent pretenses,

representations, and promises, in violation of Title 18, United

States Code, Sections 1344.

Purpose of the Conspiracy

32. The purpose of the conspiracy was for KING, L.J., L.B ., and others

known and unknown to the Grand Jury to fraudulently obtain PPP funds to which

KING was not entitled, through false and fraudulent statements, representations,

and supporting documents.

Manner and Means of the Conspiracy

33. KING, L.J., L.B., and others known and unknown to the Grand Jury

carried out the objectives of the conspiracy in the manner and means as set forth in

paragraphs 5 through 17 of this Indictment.

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

COUNT TWO

34. Introductory paragraphs 5 through 17 are realleged and incorporated

into this Count as factual allegations by reference as if fully set forth herein. It is

further alleged that the Defendant, DARNELL WILLIAM KING, L.J., L.B., and

others known and unknown to the Grand Jury, carried out the scheme and artifice

to defraud in the manner and means as set forth in those paragraphs.

35. Benworth Capital Partners, LLC is a "financial institution," as that

term is defined in Title 18, United States Code, Section 20.

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36. From in or about March 2021 to in or about November 2021, within the

Eastern District of North Carolina and elsewhere, the Defendant, DARNELL

WILLIAM KING, aiding and abetting others, executed and attempted to execute a

scheme and artifice to defraud Benworth Capital Partners, LLC-a financial

institution-by causing a loan application to be submitted which contained false

and fraudulent representations as to the Defendant's purported income prior to the

COVID-19 pandemic and other false information, resulting in the disbursement of

loan proceeds owned by, and under the custody and control of Benworth Capital

Partners, LLC.

All in violation of Title 18, United States Code, Sections 1344 and 2

COUNT THREE

37. Introductory paragraphs 5 through 17 are realleged and incorporated

into this Count as factual allegations by reference as if fully set forth herein.

The Scheme to Defraud

38. From in or about March 2021 to in or about November 2021, in the

Eastern District of North Carolina and elsewhere, the Defendant, DARNELL

WILLIAM KING, aiding and abetting others, knowingly devised and intended to

devise a scheme and artifice to defraud the SBA and Bentworth Capital Partners,

LLC, and to obtain PPP loan proceeds by means of materially false and fraudulent

representations and promises.

Case 5:24-cr-00156-M-KS Document 1 Filed 05/07/24 Page 11 of 19
Manner and Means

39. The Defendant, DARNELL WILLIAM KING, aiding and abetting

others, carried out the scheme and artifice to defraud in the manner and means as

set forth in paragraphs 5 through 17.

Use of the Wires

40. On or about April 18, 2021, in the Eastern District of North Carolina

and elsewhere , the Defendant, DARNELL WILLIAM KING, for the purpose of

executing and attempting to execute the scheme and artifice to defraud described

above, and to obtain money and property by means of materially false and

fraudulent pretenses, representations, and promises, aiding and abetting others,

did knowingly transmit and cause to be transmitted by means of wire

communication in interstate commerce, a PPP application transmitted to and

through the SBA's electronic servers in Oregon and Virginia for the purpose of

executing such scheme and artifice to defraud.

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

COUNT FOUR

41. Introductory paragraphs 5 through 17 are realleged and incorporated

into this Count as factual allegations by reference as if fully set forth herein.

42. From in or about March 2021 through in or about May 2021, within

the Eastern District of North Carolina and elsewhere , the Defendant, DARNELL

WILLIAM KING, aiding and abetting others, did knowingly make and cause to be

Case 5:24-cr-00156-M-KS Document 1 Filed 05/07/24 Page 12 of 19
made false statements and reports, for the purpose of influencing in any way

Benworth Capital Partners, a mortgage lending business as that term is defined in

Title 18 United States Code, Sections 27 and 1014, upon an application, advance,

commitment, and loan for himself, in that the Defendant falsely claimed he had

made $78,100 in gross earnings as an Uber driver, when in truth and in fact, as the

Defendant well knew, he did not earn such legitimate income as an Uber driver.

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

COUNT FIVE

43. Introductory paragraphs 18 through 29 are realleged and incorporated

into this count as factual allegations by reference as if fully set forth herein.

44. From in or about December 2021 through in or about February 2022,

in the Eastern District of North Carolina and elsewhere, the Defendant DARNELL

WILLIAM KING did knowingly combine, conspire, confederate, agree, and have a

tacit understanding with L.J., and others known and unknown to the Grand Jury,

to commit offenses against the United States, specifically: to knowingly devise and

intend to devise a scheme and artifice to defraud various private lenders, and to

obtain money and property in the form of personal lines of credit, by means of

materially false and fraudulent pretenses, representations, and promises; and for

the purpose of executing the scheme, caused to be transmitted by means of wire

communication in interstate commerce any writings, signals, signs pictures, and

sounds, in violation of Title 18, United States Code, Section 1343.

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Purpose of the Conspiracy

45. The purpose of the conspiracy was for KING, L.J., and others known

and unknown to the Grand Jury, to fraudulently obtain personal lines of credit,

through false and fraudulent statements, representations, supporting documents

and stolen PII.

Object of the Conspiracy

46. KING, L.J., and others known and unknown to the Grand Jury,

carried out the objectives of the conspiracy in the manner and means as set forth in

paragraphs 18 through 29 of this Indictment.

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

COUNT SIX THROUGH THIRTEEN

47. Introductory paragraphs 18 through 29 are realleged and incorporated

into this count as factual allegations by reference as if fully set forth herein.

The Scheme to Defraud

48. From in or about December 2021 through in or about February 2022,

within the Eastern District of North Carolina and elsewhere, the Defendant,

DARNELL WILLIAM KING, aiding and abetting others, knowingly devised and

intended to device a scheme and artifice to defraud various consumer lenders by

submitting and causing to be submitted fraudulent loan applications containing

stolen PII; and to obtain money and property in the form of loan proceeds by means

of materially false and fraudulent representations and promises.

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Manner and Means

49. The Defendant, DARNELL WILLIAM KING, carried out the scheme

and artifice to defraud in the manner and means set forth in paragraphs 18 through

29.

U se of Th e Wires

50. On or about each of the dates set forth below in the Eastern District of

North Carolina and elsewhere, the Defendant, DARNELL WILLIAM KING, for the

purpose of executing and attempting to execute the scheme and artifice to defraud

described above, caused to be transmitted by means of wire communication in

interstate commerce t he signals, writings, signs, pictures, and sounds described

below for each count, each transmission constituting a separate count:

Count Approximat;e Descriptio n Purported Identity
Date of Applicant

Fraudulent credit application submitted
6 December 15, W.J.
online to Lendmark Financial Services,
2021
LLC resulting in disbursement of $7,471.13

Fraudulent credit application submitted
7 December 22, L.B.
online to Lendmark Financial Services,
2021
LLC resulting in disbursement of $6,500

Fraudulent credit application submitted
8 December 28, R.C.
online to Lendmark Financial Services,
2021
LLC resulting in disbursement of $6,500

January 19, Fraudulent credit application submitted
9 T.P.
online to Lendmark Financial Services,
2022
LLC resulting in disbursement of $6,500

February 14, Fraudulent credit application submitted
10 N.L.
online to Time Financing Service resulting

Case 5:24-cr-00156-M-KS Document 1 Filed 05/07/24 Page 15 of 19
2022 in disbursement of $5,728.34

February 15, Fraudulent credit application submitted
11
online to OneMain Financial resulting in N.L.
2022
disbursement of $7,500

12 February 24, Fraudulent credit application submitted
N.L.
2022 online to Century Finance, Inc. resulting in
disbursement of $3,519.51

13 February 25, Fraudulent credit application submitted N.L.
2022 online to Regional Finance, Inc. resulting
in disbursement of $10,000

Each row of the foregoing table representing a separate violation of Title 18,

United States Code , Sections 1343 and 2.

COUNTS FOURTEEN THROUGH EIGHTEEN

51. Introductory paragraphs 18 through 29 are realleged and incorporated

into this count as factual allegations by reference as if fully set forth herein.

52. From in or about December 2021 through in or about February 2022,

in the Eastern District of North Carolina and elsewhere, the Defendant, DARNELL

WILLIAM KING, did knowingly transfer, possess, and use, without lawful

authority, a means of identification of another person, to wit-the name, date of

birth, and/or social security number of said other person-during and in relation to

the crimes set forth in the corresponding counts of this Indictment identified in the

table below, which are felony violations enumerated in Title 18, United States Code,

Section 1028A(c), knowing that the means of identification belonged to another

actual person.

Case 5:24-cr-00156-M-KS Document 1 Filed 05/07/24 Page 16 of 19
Count Victim Initials Corresponding Counts Predicate Offenses

14 W.J. 6 Wire Fraud (18 U.S.C. § 1343)

15 L.B . 7 Wire Fraud (18 U.S.C. § 1343)

16 R.C. 8 Wire Fraud (18 U.S.C. § 1343)

17 T.P. 9 Wire Fraud (18 U.S.C. § 1343)

18 N.L. 10, 11, 12, 13 Wire Fraud (18 U.S.C. § 1343)

All in violation of Title 18, United States Code, Section 1028A(a)(l).

COUNT NINETEEN

53. On or about October 20, 2022 , in the Eastern District of North

Carolina, the defendant, DARNELL WILLIAM KING, knowing he had previously

been convicted of a crime p unishable by imprisonment for a term exceeding one (1)

year, knowingly possessed a firearm-to wit, a CZ Model Scorpion Evo, 9mm

pistol-and the firearm was in and affecting commerce , in violation of Title 18,

United States Code, Sections 922(g)(l) and 924.

Case 5:24-cr-00156-M-KS Document 1 Filed 05/07/24 Page 17 of 19
FORFEITURE NOTICE

Notice is hereby given that all right, title and interest m the property

described herein is subject to forfeiture.

Upon conviction of any of Counts One through Four, the defendant shall

forfeit to the United States, pursuant to 18 U.S.C. § 982(a)(2)(A), any property

constituting, or derived from, proceeds obtaine d directly or indirectly as a result of

the said violation.

Upon conviction of any of Counts Five through Thirteen, the defendant shall

forfeit to the United States, pursuant to 18 U.S.C. § 981(a)(l)(C), as made

applicable by 28 U.S.C. § 2461(c), any property, real or personal, which constitutes

or is derived from proceeds traceable to the said offense.

Upon conviction of Count Nineteen or any violation of the Gun Control Act,

the National Firearms Act, or any other offense charged herein that involved or was

perpetrated in whole or in part by the use of firearms or ammunition, the defendant

shall forfeit to the United States, pursuant to 18 U.S.C. § 924(d) and/or 26 U.S.C.

§ 5872, as made applicable by 28 U.S.C. § 2461(c), any and all firearms and

ammunition that were involved in or used in a knowing or willful commission of the

offense, or, pursuant to 18 U.S.C. § 3665, that were found in the possession or under

the immediate control of the defendant at the time of arrest.

The forfeitable property includes, but is not limited to, the following:

Case 5:24-cr-00156-M-KS Document 1 Filed 05/07/24 Page 18 of 19
Forfeiture Money Judgment:

a) A sum of money representing the gross proceeds of the offense(s) charged

herein against DARNELL WILLIAM KING in the amount of at least

$633,396.

Personal Property

b) One CZ Model Scorpion Evo, 9mm pistol, bearing serial number F329589,

seized on October 20, 2022 from DARNELL WILLIAM KING and any and

all associated ammunition

If any of the above-described forfeitable property, as a result of any act or

omission of a defendant: cannot be located upon the exercise of due diligence; has

been transferred or sold to, or deposited with, a third party; has been placed beyond

the jurisdiction of the court; has been substantially diminished in value; or has been

commingled with other property which cannot be divided without difficulty; it is the

intent of the United States, pursuant to Title 21, United States Code, Section

853(p), to seek forfeiture of any other property of said defendant up to the value of

the forfeitable property described above.

MICHAEL F. EASLEY, JR
United States Attorney

BY:
D~
Assistant United States Attorney

Case 5:24-cr-00156-M-KS Document 1 Filed 05/07/24 Page 19 of 19

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