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Home Source documents Indictment — United States v. Chad M. Schampers, Nathaniel R. Smith, Gina L. Schampers and Jeffrey M. O’Brien (Dkt. 1, E.D. Wis.)

Indictment — United States v. Chad M. Schampers, Nathaniel R. Smith, Gina L. Schampers and Jeffrey M. O’Brien (Dkt. 1, E.D. Wis.)

Summary

This indictment, filed on 02/01/22 in the Eastern District of Wisconsin (Case 1:22-cr-00030-WCG-NJ), charges Chad M. Schampers, Nathaniel R. Smith, Gina L. Schampers and Jeffrey M. O’Brien with conspiracy to commit wire and bank fraud and nine counts of wire fraud. It alleges that, beginning in 2018 and continuing through at least October 2019, the defendants ran Summit Contracting, Inc., a home remodeling business, and used deceptive tactics and false statements to get customers to finance projects through EnerBank USA and GreenSky. According to the indictment, sales representatives encouraged applicants to misrepresent their annual income and funds were withdrawn from customers' financing accounts before any work began. The defendants allegedly obtained and attempted to obtain more than $1,500,000; the wire fraud counts list contracts from $10,992.03 to $62,968.

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UNITED STATES DISTRICT COURT = SLERK USDC EDW
EASTERN DISTRICT OF WISCONSIN “1 ET

122 FEB-1 PIS
UNITED STATES OF AMERICA,
Plaintiff,

Vv. Case No. 22-CR- 2 0 ~(R-30
CHAD M. SCHAMPERS, [18 U.S.C. §§ 1343, 1344(2), and
NATHANIEL R. SMITH, 1349]

GINA L. SCHAMPERS, and
JEFFREY M. O’BRIEN,
Defendants.
INDICTMENT
COUNT ONE
(Conspiracy to Commit Wire and Bank Fraud)
THE GRAND JURY CHARGES THAT:
lL Beginning in 2018 and continuing through at least October 2019, in the State and

Eastern District of Wisconsin and elsewhere,

CHAD M. SCHAMPERS,

NATHANIEL R. SMITH,

GINA L. SCHAMPERS, and

JEFFREY M. O’BRIEN
knowingly conspired with each other and persons known and unknown to the grand jury to
defraud homeowners, financial institutions, and others by means of interstate wire
communications, and by concealing material facts from federally insured financial institutions, in
violation of Title 18, United States Code, Sections 1343, 1344(2), and 1349.

Ds At all times material to this indictment:

a. The above-named defendants operated, directed, supervised, and worked

Case 1:22-cr-00030-WCG-NJ Filed 02/01/22 Page1of6 Document 1
at a home remodeling business in the Eastern District of Wisconsin operating under the name
Summit Contracting, Inc. (“Summit”).

b. Summit utilized EnerBank USA (“EnerBank”) and Green Sky, Inc.
(“GreenSky”), which are third parties who offer home improvement loans funded by a variety of
participating financial institution lenders. The lenders who ultimately provided funds to
Summit's customers are each a “financial institution” within the meaning of Title 18, United

States Code, Section 20, and their deposits are insured by the Federal Deposit Insurance

Corporation.
c. EnerBank’s corporate offices are located in Salt Lake City, Utah.
d, GreenSky’s corporate offices are located in Atlanta, Georgia.
Purpose, Manner & Means of the Conspiracy
3 The purpose of the conspiracy was to carry out a scheme to defraud and obtain

money from home improvement customers using materially false and fraudulent pretenses,
representations, and concealments, essentially as follows:

a. Chad M. Schampers, Nathaniel R. Smith, Gina L. Schampers, Jeffrey
O’Brien, and others working at their direction sought out home improvement customer leads via
television advertisements, promotional booths at local sporting events, home improvement
shows, and internet-based advertisements.

b. Chad M. Schampers, Nathaniel R. Smith, Gina L. Schampers, Jeffrey
O’Brien, and others working at their direction scheduled sales appointments in prospective
customers’ home. Sales representatives, working at the direction of the defendants, utilized high
pressure, deceptive tactics, and false statements to induce prospective customers to retain

Summit for their home improvement project.

Case 1:22-cr-00030-WCG-NJ Filed 02/01/22 Page 2 of6 Document 1
G; The defendants and others working at their direction pressured prospective
customers to finance their projects with Summit, using Summit’s chosen financial institutions,
EnerBank and GreenSky.

d. At the defendants’ direction, Summit sales representatives induced
customers to apply for financing by misrepresenting the terms of the financing being offered.

e: Summit sales representatives utilized electronic devices and tablets to
immediately process, at the sales meeting, via the interstate wires, financing applications with
EnerBank and GreenSky, and encouraged applicants to misrepresent their annual income to
ensure approval of the loan.

f. Contrary to the terms of the agreements between Summit, Enerbank,
GreenSky, and the customers, Chad M. Schampers, Nathaniel R. Smith, Gina L. Schampers, and
others withdrew funds from customer’s financing accounts prior to beginning any work and
ordering the necessary building materials.

g. Summit sales representatives repeatedly misled customers and prospective
customers as to the nature of the paperwork they were signing. At times, customers were
fraudulently induced into signing paperwork acknowledging that Summit's work on a project
was completed within hours after the sales representative met the customer for the initial sales
pitch.

h. Summit sales representatives falsely told customers and potential
customers that Summit did not use subcontractors when, in fact, a majority of Summit’s work
was performed by subcontractors,

4. As a result of the defendants’ actions, they wrongfully obtained and attempted to

obtain more than $1,500,000.

Case 1:22-cr-00030-WCG-NJ Filed 02/01/22 Page 3o0f6 Document 1
All in violation of Title 18, United States Code, Section 1349.

Case 1:22-cr-00030-WCG-NJ Filed 02/01/22 Page 4of6 Document 1
COUNTS TWO —- TEN

(Wire Fraud)

THE GRAND JURY FURTHER CHARGES THAT:

On or about the below-listed dates, in the State and Eastern District of Wisconsin

and elsewhere,

CHAD M. SCHAMPERS,
NATHANIEL R. SMITH,
GINA L. SCHAMPERS, and

JEFFREY M. O'BRIEN,

for the purpose of executing the scheme to defraud described in paragraphs 3 and 4, and with the

intent to defraud knowingly caused to be transmitted in interstate commerce wire

communications originating from the Eastern District of Wisconsin related to the recruitment of

customers, financing of home improvement loans, and receiving payment of uncompleted and

partially completed projects:

Count | ContractDate | Customer Repair(s) Contract Amount
Two January 14, 2019 D.H. Roof $21,894
Three February 3,2019 | S.K. & A.K. Roof & Skylight $14,072

Four February 12, 2019 J.D. Roof $17,438

Five March 26, 2019 T.M. Roof $12,578

Six April 5, 2019 L.J. Roof $10,992.03
Seven April 11, 2019 MLK. Roof $18,000
Eight April 18, 2019 P.R. & ALR. Chimney $17,325

Nine April 19, 2019 C.L. & F.M. Roof $62,968

Ten May 18, 2019 C.B. Roof & Windows $40,652

Each in violation of Title 18, United States Code, Sections 1343 and 2(a).

Case 1:22-cr-00030-WCG-NJ Filed 02/01/22 Page 5of6 Document 1
Cy

FORFEITURE NOTICE

l. Upon conviction of one or more of the offenses alleged in Counts One through
Ten of this Indictment, the defendant shall forfeit to the United States, pursuant to 28 U.S.C. §
246 l(c), 18 U.S.C. § 981(a)(1)(C), and 21 U.S.C. § 853, all property, real and personal, that
constitutes or is derived, directly or indirectly, from proceeds traceable to the commission of the
offenses, including, but not limited to, the following:

A sum of money representing the amount of proceeds the defendant obtained as a result
of his wire, mail, or financial institution fraud scheme.

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

of the defendant:

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

b. has been transferred or sold to, or deposited with, a third party;

C; has been placed beyond the jurisdiction of the court;

d. has been substantially diminished in value; or

€. has been commingled with other property, which cannot be divided without
difficulty;

it is the intent of the United States, pursuant to 21 U.S.C. § 853(p), as incorporated by 28 U.S.C.

§ 2461(c), to seek forfeiture of any other property of the defendant up to the value of the

A - BILL:

FOREPERSON

RICHARD G. FROHLING /
United States Attorney

forfeitable property described above.

Case 1:22-cr-00030-WCG-NJ Filed 02/01/22 Page 6of6 Document 1

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