Indictment — USA v. Campbell et al (Dkt. 1, D. Kan.)
Summary
An Indictment in United States of America v. Joseph Campbell and John Duncan, Case No. 25-20099-HLT-ADM-1-2, in the U.S. District Court for the District of Kansas, Document 1, filed 12/17/25 in Case 2:25-cr-20099-HLT. The Indictment alleges a scheme beginning in and around March 2020 and continuing until at least December 28, 2020 to defraud the SBA through PPP and EIDL loan applications containing materially false information. It alleges that Campbell and Duncan, through Campbell's companies, applied for twelve PPP loans and twenty-four EIDL loans, and that approximately $273,383 in PPP proceeds and approximately $1,761,100 in EIDL proceeds were received. Count 1 charges Wire Fraud Conspiracy under 18 U.S.C. § 1349, and the penalty pages list Counts 2-7 as Money Laundering and Counts 14-15 as Making a False Statement.
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“Indictment — USA v. Campbell et al (Dkt. 1, D. Kan.).”
Original at ecf.ksd.uscourts.gov. Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/indictment-usa-v-campbell-et-al-dkt-1-d-kan-0c159266e9/
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Case 2:25-cr-20099-HLT Document 1 Filed 12/17/25 Page 1 of 19
UNITED STATES DISTRICT COURT
District of Kansas
(Kansas City Docket)
UNITED STATES OF AMERICA,
Plaintiff,
v. CASE NO. 25-20099-HLT-ADM-1-2
JOSEPH CAMPBELL
and
JOHN DUNCAN,
Defendants.
INDICTMENT
THE GRAND JURY CHARGES:
At all times relevant to this Indictment:
BACKGROUND
1. 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
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businesses and by assisting in the economic recovery of communities after disasters. As
part of this effort, the SBA enabled and provided for loans through banks, credit unions,
and other lenders. These loans have government-backed guarantees.
2. Defendant Joseph Campbell was a resident of Kansas. Defendant Campbell
owned several real estate, development, sales and asset acquisition businesses.
3. Defendant John Duncan was a resident of Kansas. Duncan was employed by
Campbell.
4. Titan Fish Partners, LLC was one of Defendant Campbell’s businesses. It
was organized on January 10, 2017, with Defendant Campbell listed as its resident agent
and organizer.
5. Titan Fish One, LLC was another of Defendant Campbell’s businesses. It
was organized on October 1, 2014, with Campbell listed as the registered agent and
organizer.
6. Titan Fish Two, LLC was another of Defendant Campbell’s businesses. It
was organized in March 2015, with Campbell listed as the organizer. It was forfeited on
October 15, 2020.
7. Titan Fish Three, LLC was another of Defendant Campbell’s businesses. It
was organized in October 2015, with Kansas Corporation #2, Inc. listed as the organizer.
It was forfeited on July 15, 2022.
8. Titan Fish Four, LLC was another of Defendant Campbell’s businesses. It
was organized in October 2015, with Kansas Corporation #2, Inc. listed as the organizer.
It was forfeited on July 15, 2022.
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9. Kansas City Cattle Co. LLC was another of Defendant Campbell’s
businesses. It was organized on October 1, 2014, with Campbell listed as the registered
agent and organizer. It was forfeited on July 15, 2016.
10. Pate-Campbell Properties, Inc., was another of Campbell’s businesses. It
was registered as a corporation with the Kansas Secretary of State in 2001. Its status was
forfeited in October 2020 for failure to file its annual report. Campbell was listed as its
director, president, and secretary.
11. Terra Vista Development was another of Campbell’s businesses. It was
organized in May 2000, with Campbell listed as the only member and manager.
12. Jacobson-Campbell Excavation, Inc. was another of Campbell’s businesses.
It was registered as a corporation with the Kansas Secretary of State in 1999.
13. Crossings of Spring Hill, LLC was another of Campbell’s businesses. It was
organized in October 2005, with Campbell listed as the organizer.
14. Ewing III Land Company, LLC was another of Campbell’s businesses. It
was organized in August 2009, with Campbell listed as the organizer.
15. Ewing 3 Development, LLC was another of Campbell’s businesses. It was
organized in April 2001, with Pate-Campbell Properties, Inc. and two other entities listed
as the members of the entity.
16. Rockwood at Prairie Highlands, LLC was another of Campbell’s businesses.
It was organized in October 2005, with Campbell listed as the organizer. It was forfeited
on July 15, 2018.
17. HTCBGCC AMALFI, LLC was another of Campbell’s businesses. It was
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organized in May 2017, with Campbell listed as the organizer. It was forfeited on October
15, 2020.
18. CML-2015-TF, LLC, was another of Campbell’s businesses. It was
organized in June 2016, with Kansas Corporation #2, Inc. as the organizer.
19. CML 2015-MM-T LLC, was another of Campbell’s businesses. It was
organized in September 2015, with Kansas Corporation #2, Inc. as the organizer. It was
forfeited on July 15, 2022.
20. Kansas Corporation #2 was a Kansas for profit corporation.
21. The Coronavirus Aid, Relief, and Economic Security (“CARES”) Act was a
federal law enacted in March 2020, and, among other things, was designed to provide
emergency financial assistance to the millions of Americans who were suffering the
economic effects caused by the COVID-19 pandemic. One source of relief provided by
the CARES Act was the authorization of forgivable loans to small businesses for job
retention and certain other expenses, through a program referred to as the Paycheck
Protection Program (“PPP”).
22. To obtain a PPP loan, a qualifying business was required to submit a PPP
loan application, which was signed by an authorized representative of the business. The
PPP loan application required the business, through its authorized representative, to
acknowledge the program rules and make certain affirmative certifications in order to be
eligible to obtain the PPP loan. In the PPP loan application, the small business was
required to state, among other things, its: (a) average monthly payroll expenses; and (b)
number of employees. These figures were used to calculate the amount of money the
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small business was eligible to receive under the PPP. In addition, businesses applying for
a PPP loan were required to provide documentation showing their payroll expenses,
typically this would include payroll expenses reported to the IRS by way of filed tax
returns.
23. When a PPP loan application was approved, the participating lender funded
the PPP loan using its own monies, which were guaranteed by the SBA. Data from the
application, including information about the borrower, the total amount of the loan, and
the number of employees, was transmitted by the lender to the SBA in the course of
processing the loan.
24. PPP loan proceeds were required to be used for certain permissible expenses,
including payroll costs, mortgage interest, rent, and utilities. 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 expense items within a designated period
of time and used a certain portion of the loan towards payroll expenses.
The Economic Injury Disaster Loan (“EIDL”) Program
25. The Economic Injury Disaster Loan (“EIDL”) Program, which was
administered through the Small Business Administration (“SBA”), offered loans to small
business owners who had suffered an economic loss during a natural disaster. Congress
expanded the financial resources of the EIDL program when it enacted the CARES Act.
Under the CARES Act, the EIDL program expanded its eligibility to include loans for non-
profit organizations, sole proprietors, and independent contractors. The CARES Act also
authorized the SBA to provide EIDL loans up to $2 million per loan. The CARES Act
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authorized the SBA to issue loan advances up to $10,000 to small entities. The amount of
the advance was determined by an entity’s number of employees and the advances do not
have to be repaid.
26. In order to obtain an EIDL loan and/or advance, a qualifying business must
have submitted an application to the SBA and provide particular information about its
operations, such as the number of employees, and the gross revenues and costs of goods
sold for the 12-month period preceding January 31, 2020. If the application was approved,
the amount of the loan was determined, in part, on the information provided by the
applicant about the employment, revenue, and cost of goods as described above. The loan
applicant must also certify that all information provided in the application was true and
correct to the best of the applicant’s knowledge.
27. EIDL applications were submitted directly to the SBA. Further, any funds
issued under an EIDL loan or advance were issued directly by the SBA. EIDL funds could
be used for payroll expenses, sick leave, production costs, and fixed debts, such as utilities,
rent, and mortgage payments.
THE WIRE FRAUD SCHEME AND CONSPIRACY
28. Beginning around February 2019, Defendant Campbell hired Defendant
Duncan, to work for Titan Fish Partners. Duncan’s title was Construction Manager, but
Campbell referred to him as CFO.
29. Beginning in and around March 2020 and continuing until at least December
28, 2020, Campbell and Ducan devised a scheme to defraud SBA by submitting PPP and
EIDL loan applications that contained materially false information. As further part of the
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scheme to defraud, Campbell used the PPP and EIDL loan proceeds for purposes other than
authorized by the PPP and EIDL loan programs, including personal expenses.
29. Campbell and Duncan, through Campbell’s companies, applied for twelve
PPP loans. Eleven of the loans were funded, and Campbell and his companies received
approximately $273,383 in PPP loan proceeds.
30. Campbell and Duncan, through Campbell’s companies, applied for twenty-four
EIDL loans. However, only five of the loan applications were funded, and Campbell and
his companies received approximately $1,761,100 in EIDL loan proceeds.
The false statements
31. In the twelve PPP loan applications Campbell and Duncan submitted for
Campbell’s companies, they were required to state the average monthly payroll for each
business on the applicable PPP loan application. The applications claimed total payroll of
more than $900,000 per year for the businesses. However, the applications falsely stated
the monthly payroll for each company. For instance, PPP loan applications for Titan Fish
Partners, the application listed an average monthly payroll of $17,224 and $17,240 per
month, which would mean the company had annual payroll expenses or more than
$200,000. However, records from payroll companies used by Titan Fish Partners establish
that Titan Fish Partners had an annual payroll of $51,600 in 2019 and $46,100 in 2020.
32. On or about April 27, 2020, Campbell, as managing member of Titan Fish
One, LLC, applied for a PPP loan with Landmark Bank. In the PPP application, Campbell
falsely claimed that Titan Fish One, LLC had average monthly payroll of approximately
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$8,333. This was a false statement because, as Campbell knew, Titan Fish One, LLC had
no payroll expenses at the time.
33. On or about May 9, 2020, Campbell, through Ewing III Land Company,
LLC, applied for a PPP loan with Kabbage Inc. In the PPP application, Campbell falsely
claimed that Ewing III Land Company, LLC had average monthly payroll of approximately
$8,333. This was a false statement because, as Campbell knew, Ewing III Land Company,
LLC had no payroll expenses at the time.
34. On or about January 20, 2021, Campbell, through Pate-Campbell Properties,
applied for a PPP loan with Cross River Bank. In the PPP application, Campbell falsely
claimed that Pate-Campbell Properties had average monthly payroll of approximately
$8,333. This was a false statement because, as Campbell knew, Pate-Campbell Properties
had no payroll expenses at the time. At the time Pate-Campbell was not actively engaged
in business activity.
35. On or about February 24, 2021, Campbell and Duncan applied for a PPP loan
through Kansas City Cattle Company, LLC with DreamSpring. At the time Kansas City
Cattle Company, LLC was not actively engaged in business. In the PPP Application
Campbell and Duncan falsely claimed that Kansas City Cattle Company had average
monthly payroll of $8,333. As part of the PPP loan application, Duncan created a false
invoice that showed cattle being purchased for $12,166.25. The invoice was false because
no such sale took place. The invoice was presented as part of the PPP loan application.
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Campbell and Duncan both knew there was no such sale of cattle and the invoice was
fraudulent.
37. As part of the EIDL application process, Campbell communicated with SBA
employees. On May 6, 2020, Campbell emailed an SBA employee and stated, “Kansas
City Cattle, LLC cost of operations was $210,414 for 2019.” This was a false statement.
38. Campbell submitted an EIDL loan application for Terra Vista Development.
However, SBA denied the loan because the application accurately stated that Terra Vista
was a real estate development company and therefore did not qualify for EIDL loans.
Following this notice, Campbell made false representations to SBA about the true nature
of his companies in order for them to qualify for EIDL loans. For instance, in order to
qualify for an EIDL loan, Campbell falsely stated that Pate-Campbell was a custom-home
builder, when Pate-Campbell actually was a real estate development company.
Campbell’s usage of PPP and EIDL loan proceeds
39. Instead of using the EIDL proceeds to pay for payroll expenses, sick leave,
production costs, or fixed debts, such as utilities, rent, and mortgage payments, Campbell
used much of the proceeds for personal expenses.
40. On May 13, 2020, using EIDL proceeds, Campbell caused a cashier’s
check to be paid to Olathe Dodge in the amount of $36,000. Defendant purchased a 2019
Dodge Ram 1500.
41. On May 26, 2020, Defendant used EIDL loan proceeds to purchase a piece
of real property located at the Lake of the Ozarks.
42. On July 3, 2020, using EIDL proceeds, Campbell caused a cashier’s check
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to be paid to Olathe Ford in the amount of $22,334.81. The proceeds were used to
purchase a 2017 Ford Explorer.
Loan forgiveness
43. On or about December 28, 2020, Campbell, through Titan Fish One, LLC,
provided Landmark Bank, a financial institution, with a PPP Loan Forgiveness
Application. In the form, Campbell sought loan forgiveness for $20,800 PPP loan. In the
loan forgiveness application, Campbell falsely claimed that he had used the PPP loan to
pay costs that were eligible for forgiveness (payroll costs to retain employees; business
mortgage interest payments; business rent or lease payments; or business utility
payments). He also falsely claimed that the PPP loan amount included payroll costs equal
to at least 60% of the forgiveness amount. In actuality, Titan Fish One, LLC did not have
any payroll and was not therefore eligible for the PPP loan or for forgiveness of the PPP
loan.
COUNT 1
Wire Fraud Conspiracy
[18 U.S.C. § 1349]
44. Paragraphs 1 through 43 are realleged and incorporated herein.
45. Beginning on a date unknown, but no later than on or about February 24,
2020, and continuing through at least December 28, 2020, in in the District of Kansas and
elsewhere, the defendants,
JOSEPH CAMPBELL
and
JOHN DUNCAN,
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did knowingly and willfully combine, conspire, confederate, agree, and have a tacit
understanding with each other, to devise and intend to devise a scheme and artifice to
defraud, and to obtain money and property, by means of materially false and fraudulent
pretenses, representations, and promises, and by omission of material facts, well knowing
and having reason to know that said pretenses were and would be false and fraudulent
when made and caused to be made and that said omissions were and would be material,
and, in so doing, caused interstate and foreign wire communications to be made, in
furtherance of the scheme and artifice to defraud, in violation of Title 18, United States
Code, Section 1343.
This was in violation of Title 18, United States Code, Section 1349.
COUNTS 2 THROUGH 7
Money Laundering
[18 U.S.C. § 1957]
46. Paragraphs 1 through 45 are incorporated and realleged herein.
47. On or the dates listed in the table below, in the District of Kansas and
elsewhere, the defendant,
JOSEPH CAMPBELL,
knowingly conducted and attempted to conduct a financial transaction affecting interstate
commerce, in criminally derived property of a value greater than $10,000, as set forth in
the table below, such property having been derived from specified unlawful activity, that
is, wire fraud conspiracy in violation of 18 U.S.C. § 1349.
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Count Date Financial transaction
Two May 13, 2020 Transfer of approximately $36,000 via
cashier’s check to Olathe Dodge
Three May 19, 2020 Transfer of approximately $14,000 via
cashier’s check payable to Campbell’s spouse
Four May 26, 2020 Transfer of approximately $20,000 via
cashier’s check payable to Campbell’s spouse
Five June 1, 2020 Transfer of approximately $16,599.99 to Metro
Ford for the purchase of a Mustang
Six June 16, 2020 Transfer of approximately $25,0000 via
cashier’s check payable to Campbell’s daughter
and son-in-law
Seven July 3, 2020 Transfer of approximately $22,331.81 to Olathe
Ford
In violation of Title 18, United States Code, Sections 1957 and 2.
COUNTS 8 THROUGH 13
False Statement in a Loan Application
[18 U.S.C. § 1014]
48. Paragraphs 1 through 47 are incorporated and realleged herein.
49. On or about the dates listed in the table below, in the District of Kansas and
elsewhere, the defendant,
JOSEPH CAMPBELL,
knowingly made a false statement for the purpose of influencing the action of a financial
institution whose accounts are insured by the Federal Deposit Insurance Corporation, in
connection with a PPP application and loan, as set forth in the table below:
Count Date Financial False statement(s)
Institution
Eight April 27, Landmark Campbell falsely stated that Titan Fish One,
2020 Bank LLC had average monthly payroll of
approximately $8,333 and that Campbell was
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not an owner of any other business
Nine June 30, Radius Campbell falsely stated that Jacobson-
2020 Bank Campbell Excavation, LLC had average
monthly payroll of approximately $8,333 and
that Campbell was not an owner of any other
business
Ten December Landmark In a PPP loan forgiveness application for
28, 2020 National Titan Fish One, LLC, Campbell falsely stated
Bank that the dollar amount for which forgiveness
was requested was used to pay costs that was
eligible for forgiveness (payroll costs to retain
employees; business mortgage interest
payments; business rent or lease payments; or
business utility payments); and the dollar
amount for which forgiveness was requested
included payroll costs equal to at least 60% of
the forgiveness amount
Eleven January 15, Capitol Campbell falsely stated that Titan Fish
2021 Federal Partners, LLC had average monthly payroll of
Bank approximately $17,240 and that Campbell
was not an owner of any other business
Twelve January 16, Radius Campbell falsely stated that Jacobson-
2021 Bank Campbell Excavation, Inc. had average
monthly payroll of approximately $8,333.33
and that Campbell was not an owner of any
other business
Thirteen February 4, Northeast Campbell falsely stated that Titan Fish
2021 Bank Partners, LLC had average monthly payroll of
approximately $17,224 and that Campbell
was not an owner of any other business
This was all in violation of Title 18, United States Code, Sections 1014 and 2.
COUNT 14
Making a False Statement
[18 U.S.C. §1001(a)]
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50. On or about May 6, 2020, in the District of Kansas and elsewhere, the
defendant,
JOSEPH CAMPBELL,
did willfully and knowingly make a materially false, fictitious, and fraudulent statement
and representation in a matter within the jurisdiction of the executive branch of the
Government of the United States, by emailing to an SBA employee that Kansas City
Cattle, LLC’s costs of operations in 2019 was $210,414. That statement and
representation was false because, as Campbell then and there knew, Kansas City Cattle,
LLC did not have costs of operations in that amount.
In violation of Title 18, United States Code, Section 1001 and 2.
COUNT 15
Making a False Statement
[18 U.S.C. §1001(a)]
51. On or about May 7, 2020, in the District of Kansas and elsewhere, the
defendant,
JOSEPH CAMPBELL,
did willfully and knowingly make a materially false, fictitious, and fraudulent statement
and representation in a matter within the jurisdiction of the executive branch of the
Government of the United States, by telling an SBA employee that Pate-Campbell was a
custom home builder. That statement and representation was false because, as Campbell
then and there knew, Pate-Campbell was a real estate development company that did not
build custom homes.
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In violation of Title 18, United States Code, Section 1001 and 2.
FORFEITURE NOTICE
52. The allegations contained in paragraphs 1-51 and Counts 1-15 are hereby
realleged and incorporated by reference for the purpose of alleging forfeiture pursuant to
Title 18, United States Code, Section 981(a)(1)(C) and Sections 982(a)(1) and (2), and
Title 28, United States Code, Section 2461(c).
53. Upon conviction of the offense set forth in Count 1 of this Indictment, the
defendants shall forfeit to the United States of America, pursuant to Title 18, United
States Code, Section 981(a)(1)(C) and Title 28, United States Code, Section 2461(c), any
property, constituting, or derived from, proceeds obtained, directly or indirectly, as a
result of such violations. The property to be forfeited includes, but is not limited to, the
following:
A. A forfeiture money judgment against each defendant in an amount
equal to the amount of gross proceeds obtained or derived by that defendant
from the commission of Count 1.
54. Upon conviction of one or more of the offenses set forth in Counts 2-7 of
this Indictment, defendant Joseph Campbell shall forfeit to the United States of America,
pursuant to Title 18, United States Code, Section 982(a)(1), any property, real or
personal, involved in such offenses, or any property traceable to such property, including
but not limited to, the following:
A. A forfeiture money judgment against the defendant in an amount equal
to the value of the property involved in Counts 2-7.
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55. Upon conviction of one or more of the offenses set forth in Counts 8-13 of
this Indictment, defendant Joseph Campbell shall forfeit to the United States of America,
pursuant to Title 18, United States Code, Section 982(a)(2)(A), any property,
constituting, or derived from, proceeds obtained, directly or indirectly, as a result of such
violations. The property to be forfeited includes, but is not limited to, the following:
A. A forfeiture money judgment against the defendant in an amount equal
to the amount of gross proceeds obtained or derived by him from the
commission of Counts 8-13.
56. If any of the property described above, as a result of any act or omission
of the defendants:
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
E. has been commingled with other property which cannot be divided
without difficulty,
the United States of America shall be entitled to forfeiture of substitute property pursuant
to Title 21, United States Code, Section 853(p) as incorporated by Title 18, United States
Code, Section 982(b)(1) and Title 28, United States Code, Section 2461(c).
All pursuant to 18 U.S.C. §§ 981(a)(1)(C), 982(a)(1), and 982(a)(2)(A), and 28
U.S.C. § 2461(c).
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A TRUE BILL.
December 17, 2025 s/Foreperson
x
DATE FOREPERSON OF THE GRAND JURY
RYAN A. KRIEGSHAUSER
UNITED STATES ATTORNEY
By: /s/ D. Christopher Oakley
D. CHRISTOPHER OAKLEY
Assistant United States Attorney
District of Kansas
500 State Avenue, Suite 360
Kansas City, Kansas 66101
Ph: (913) 551-6730
Fax: (913) 551-6541
Email: chris.oakley@usdoj.gov
Ks. S. Ct. No. 19248
IT IS REQUESTED THAT THE TRIAL BE HELD IN KANSAS CITY, KANSAS
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PENALTIES
Count 1: Wire Fraud Conspiracy
• Punishable by a term of imprisonment of not more than twenty (20) years. 18
U.S.C. § 1341.
• A term of supervised release of not more than three (3) years. 18 U.S.C. §
3583(b)(2).
• A fine not to exceed $250,000. 18 U.S.C. § 3571(b)(3). In the alternative, the
defendant may be fined not more than the greater of twice the gross gain or twice
the gross loss. 18 U.S.C. § 3571(d).
• A mandatory special assessment of $100.00. 18 U.S.C. § 3013(a)(2)(A).
• Forfeiture.
Counts 2- 7: Money Laundering
• Punishable by a term of imprisonment of not more than ten (10) years. 18 U.S.C.
§ 1957(b)(1).
• A term of supervised release of not more than three (3) years. 18 U.S.C. §
3583(b)(2).
• A fine not to exceed $250,000. 18 U.S.C. § 3571(b)(3). In the alternative, the
defendant may be fined not more than twice the amount of the criminally derived
property involved in the transaction. 18 U.S.C. § 1957(b)(2)
• A mandatory special assessment of $100.00. 18 U.S.C. § 3013(a)(2)(A).
• Forfeiture.
Counts 8-13: False Statement in a Loan Application
• Punishable by a term of imprisonment of not more than thirty (30) years. 18
U.S.C. § 1014.
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• A term of supervised release of not more than five (5) years. 18 U.S.C. §
3583(b)(2).
• A fine not to exceed $1,000,000. 18 U.S.C. § 1014.
• A mandatory special assessment of $100.00. 18 U.S.C. § 3013(a)(2)(A).
• Forfeiture.
Counts 14-15: Making a False Statement
• Punishable by a term of imprisonment of not more than five (5) years. 18 U.S.C.
§ 1001.
• A term of supervised release of not more than three (3) years. 18 U.S.C. §
3583(b)(2).
• A fine not to exceed $250,000. 18 U.S.C. § 3571(b)(3).
• A mandatory special assessment of $100.00. 18 U.S.C. § 3013(a)(2)(A).
• Forfeiture.
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