Indictment — United States v. Dawnikia Bruceatte Hunt, No. 1:25CR00047-SEP-ACL (Dkt. 2, E.D. Mo.)

Summary

This indictment, filed March 4, 2025 in the Eastern District of Missouri (No. 1:25CR00047-SEP-ACL), charges Dawnikia Bruceatte Hunt, a/k/a Dawnika Hunt, of Caruthersville, Missouri with a false statement to a financial institution under 18 U.S.C. § 1014 and wire fraud under 18 U.S.C. § 1343. The grand jury charges that on or about May 1, 2021 Hunt caused a PPP loan application to be submitted to Fountainhead Small Business Finance, LLC of Lake Mary, Florida, falsely stating that Hunt ran a small business in operation in Missouri on February 15, 2020. The application was supported by a false 2019 IRS Schedule C, and the indictment says there was no such business. As a result, the lender transferred $19,960.00 to a bank account of Hunt. The forfeiture allegations seek a sum of money of at least $19,960.00.

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Case: 1:25-cr-00047-SEP-ACL Doc. #: 2 Filed: 03/04/25 Page: 1 of 7 PageID #:
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FILED

IN THE UNITED STATES DISTRICT COURT MAR O4 2025
FOR THE EASTERN DISTRICT OF MISSOURI U. S. DISTRICT COUR1
SOUTHEASTERN DIVISION EASTERN DISTRICT Of W
CAPF Gl~i-R f,..

UNITED STATES OF AMERICA, )
)
Plaintiff, )
)
vs. ) 1:25CR00047-SEP-ACL
)
DAWNIKIA BRUCEATTE HUNT, ) Title 18, U.S.C. § 1014.
a/k/a, Dawnika Hunt, ) Title 18, U.S.C. § 1343.
) Forfeiture allegations.
Defendant. )

INDICTMENT

THE GRAND JURY CHARGES THAT:

At all times material to this Indictment, unless otherwise specified below:

1. Dawnikia Bruceatte Hunt, the defendant herein, was a resident of Caruthersville, Pemiscot
County

Missouri, within the Southeastern Division of the Eastern District of Missouri.

2. Dawnikia Hunt did not own or operate a business registered or incorporated within the

State of Missouri which was in operation on February 15, 2020.

The Paycheck Protection Program

3. The United States Small Business Administration ("SBA") is an executive-branch

agency of the United States government that provides support to entrepreneurs and small

businesses. The mission of the SBA is to maintain and strengthen the nation's economy by

enabling the establishment and viability of small businesses and by assisting in economic

recove1y after disasters.

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4. The Coronavirus Aid, Relief, and Economic Security ("CARES") Act, Pub. L. No.

116-136, 134 Stat. 281 (2020), is a federal law that was enacted in or around March 2020 to

provide emergency financial assistance to the millions of Americans suffering the economic

impact caused by the COVID-1 9 pandemic. One source of relief provided for in the CARES Act

was the authorization of forgivable loans to small businesses for job retention and certain other

expenses through the Paycheck Protection Program ("PPP"). The purpose of loans issued under

the PPP was to enable small businesses suffering from the economic downturn to continue to pay

salary, wages and to provide benefits, such as health insurance coverage, to their employees.

5. To obtain a PPP loan, a qualifying business was required to submit a PPP loan

application, signed by an authorized representative of the business. The PPP loan application

required the business to acknowledge the program rules and make ce1iain affirmative

ce1tifications to obtain the PP_P loan. ln the PPP loan application (SBA Form 2483), the small

business (through its authorized representative) was required to certify: (a) that the small

business was in operation on February 15, 2020; and (b) the average monthly payroll expenses;

and (c) the nun1ber of employees. These certifications were used to calculate the amotmt of

money the small business was eligible to receive under the PPP. In addition, businesses applying

for PPP loans were required to submit documentation supporting their payroll expenses.

7. A PPP loan application was then processed by a participating lender. If a PPP loan

application was approved, the paiiicipating lender funded the loan using its own monies, which

were then guai·anteed by the SBA. Generally, in the event that the borrower defaulted on a PPP

loan, the SBA would purchase the bonower's debt from the lending financial institution and

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assume the responsibility for paying back the loan.

8. PPP loan funds were required to be used on certain permissible expenses,

including payroll costs, mortgage interest, rent, and utilities for the business. In the PPP loan

application (SBA Form 2483), the borrower must ce1iify that "[a]ll SBA loan proceeds will be

used only for business-related purposes as specified in the loan application and consistent with

the Paycheck Protection Program Rule." In that same application, the borrower must also certify

that "[t]he funds will be used to retain workers and maintain payroll or make mortgage interest

payments, lease payments, and utility payments, as specified under the Paycheck Protection

Program Rule."

9. Under the applicable PPP rules and guidance, the interest and principal on the

PPP loan was eligible for forgiveness if the business spent the loan proceeds on these authorized

expense items within a designated period of time and used a certain p01iion of the loan toward

payroll expenses.

10. Fountainhead Small Business Finance, LLC (Fountainhead), a financial institution

headquartered in Lake Mary, Florida, was a paiiicipating lender and issued PPP loans guai·anteed

by the SBA. Fountainhead processed applications for PPP loans that were submitted through an

internet-based web po1ial, which affected interstate commerce.

The Scheme to Defraud

COUNTI
False Statement (18 U.S.C. § 101 4)

11. Paragraphs 1-10 are realleged and incorporated by reference as if fully set forth herein.

12. On or about May 1, 2021 , in the Southeastern Division of the Eastern District of Missouri and

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elsewhere, the defendant, Dawnikia Hunt, knowingly made a false statement to Fountainhead

Small Business Finance, LLC, a financial institution, for the purpose of influencing the action of

Fountainhead Small Business Finance, LLC upon an application for a SBA backed PPP loan, in

violation of Title 18, United States Code, Section 1014 and punishable under Title 18, United

States Code, Section 1014.

Manner and Means

13. It was a part of the scheme that, on or about May 1, 2021 , Dawnikia Hunt caused to be

submitted a fraudulent PPP loan application on behalf of Dawnikia Hunt, which falsely stated:

a) That Dawnikia Hunt was the owner I operator of a small business that was in operation in
Missouri on February 15, 2020.

b) That any funds received by way of a PPP loan would be spent on permissible expenses,
such as payroll costs, mortgage interest, rent and utilities for the business which she
claimed.

14. Further, Dawnikia Hunt knowingly submitted and caused to be submitted certain documents

in support of the fraudulent PPP loan application, including a materially false and fraudulent

Internal Revenue Service (IRS) Schedule C (Form 1040) Profit or Loss From Business form

(Schedule C) for 2019, claiming specified amounts of income and expenses.

When in truth and fact, there was no such business and Dawnikia Hunt had not obtained
the gross income listed, nor incurred the expenses claimed, and Dawnikia Hunt did not spend the
proceeds of the loan in a manner consistent with the rules of the program.

COUNT II
Wire Fraud (18 U.S.C. § 1343)

15. Paragraphs 1-10 are realleged and incorporated by reference as if fully set forth herein.

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16. On or about May 1, 2021 , in the Southeastern Division of the Eastern District of Missouri and

elsewhere, the defendant, Dawnikia Hunt voluntarily and intentionally devised or participated in

a scheme to obtain money by means of material false representations, namely the submission of a

fraudulent PPP loan application, with the intent to defraud, and the defendant used, or caused to

be used an interstate wire communication, that is the electronic submission of a fraudulent loan

application via the internet, for the purpose of obtaining an electronic deposit of funds into a bank

account of Dawnikia Hunt, in furtherance of the scheme, and the scheme affected Fountainhead

Small Business Finance, LLC, a financial institution, in violation of Title 18 United States Code,

Section 1343 and punishable under Title 18, United States Code, Section 1343.

17. It was a part of the scheme that, on or about May 1, 2021, Dawnikia Hunt submitted and caused

to be submitted a fraudulent PPP loan application on behalf of Dawnikia Hunt, which falsely

stated:

a) That Dawnikia Hunt was the owner / operator of a small business that was in operation in
Missouri on February 15, 2020.

b) That any funds received by way of a PPP loan would be spent on permissible expenses,
such as payroll costs, mortgage interest, rent and utilities for the business which she
claimed.

18. Further, Dawnikia Hunt submitted and caused to be submitted certain documents in support of

the fraudulent PPP loan application, including a materially false and fraudulent Internal Revenue

Service (IRS) Schedule C (Form 1040) Profit or Loss From Business form (Schedule C) for 2019

which falsely represented specified amounts of income and expenses.

When in truth and fact, there was no such business and Dawnikia Hunt had not obtained

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the gross income listed, nor incurred the expenses claimed and Dawnikia Hunt did not spend the
proceeds of the loan in a manner consistent with the rules of the program.
19. As a result of the materially false and fraudulent application for a PPP loan, the lender did

electronically transfer $19,960.00 to a bank account ofDawnikia Hunt.

Forfeiture Allegations

The Grand Jury fmiher finds by probable cause that:

Pursuant to Title 18, United States Code, Section 982(a)(2)(A) and (a)(3)(F), upon

conviction of an offense in violation of Title 18, United States Code, Section 1014 and/or

Section 1343 , as set forth in the Indictment, the defendant shall forfeit to the United States of

America any prope1iy constituting, or derived from, proceeds obtained, directly or indirectly, as

a result of such violation. Subject to forfeiture is a sum of money equal to the total value of the

property, real or personal, constituting or derived from any proceeds traceable to such violation,

which is at least $19,960.00.

If any of the prope1iy described above, 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 paiiy;
c. has been placed beyond the jurisdiction of the comi;
d. has been substantially diminished in value; or
e. has been commingled with other prope1iy which caimot be divided without
difficulty,
the United States of America will be entitled to the fo1feiture of substitute property

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

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A TRUE BILL

Foreperson

SAYLER A. FLEMING
United States Attorney

Tim J. Willis, # 62428MO
Assistant United States Attorney

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