Indictment — United States v. James Sean Freeman, II, District of Nevada (Document 1)

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A grand jury indictment in United States of America v. James Sean Freeman, II, Case 2:26-cr-00107-JAD-NJK, in the United States District Court for the District of Nevada, filed June 10, 2026 as Document 1. Counts One and Two charge wire fraud under 18 U.S.C § 1343. The indictment alleges that Freeman submitted two PPP loan applications to Harvest Small Business Financing, on or about April 2, 2021 and April 10, 2021, stating he was sole proprietor of a company that did not exist and supported by a false Schedule C for tax year 2019. It alleges that Harvest deposited $16,940 for each loan into a Navy Federal Credit Union account and that, after forgiveness applications on or about October 26, 2021, the SBA paid Harvest $16,940 plus interest for each loan on or about October 29, 2021.

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“Indictment — United States v. James Sean Freeman, II, District of Nevada (Document 1).” Original at ecf.nvd.uscourts.gov. Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/indictment-usa-v-freeman-dkt-1-6adbe5a85c/, SHA-256 3577496db332e95118fa987580b01c72a5ba42c7242e1413b2ef675c34b1fdd0.

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Case 2:26-cr-00107-JAD-NJK Document1 Filed 06/10/26 Pagelof7

SEALED

Office of the United States Attorney
District of Nevada

501 Las Vegas Boulevard, Suite 1100
Las Vegas, Nevada 89101

(702) 388-6336
Case 2:26-cr-00107-JAD-NJK Document1 Filed 06/10/26 Page2of/7

TODD BLANCHE

Acting Attorney General — —————
First Assistant United States Attorney COUNSEL/PARTIES OF RECORD
District of Nevada
Nevada Bar No. 8264 IUN 10 2026
Assistant United States Attorney :
501 Las Vegas Blvd. South, Suite 1100 CLERK US UIST CT COURT

Las Vegas, Nevada 89101 BY: anaes a DEPUTY

Tel: (702) 388-6336
Fax: (702) 388-6418

Attorneys for the United States of America

UNITED STATES DISTRICT COURT
DISTRICT OF NEVADA
UNITED STATES OF AMERICA, SEALED
CRIMINAL INDICTMENT
Plaintiff,
Case No.: 2:26-cr-0107-JAD-NJK
vs.
VIOLATION:

JAMES SEAN FREEMAN, IJ,

18 U.S.C § 1343- Wire Fraud.
Defendant.

THE GRAND JURY CHARGES THAT:
At all times relevant to this Indictment:
BACKGROUND
1. Defendant James Sean Freeman, II (“Freeman”) was a resident of Las
Vegas, Nevada and Colton, California.
2. Harvest Small Business Financing (“Harvest”) was a non-bank commercial
mortgage lender headquartered in headquartered in Laguna Hills, California that

participated as a lender in the Paycheck Protection Program.
Case 2:26-cr-00107-JAD-NJK Document1 Filed 06/10/26 Page 3of/7

Background Regarding the Paycheck Protection Program

3. The Coronavirus Aid, Relief, and Economic Security (“CARES”) Act is a
federal law enacted in or around March 2020 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 up to $349 billion in forgivable loans to small businesses and sole
proprietorships for job retention and certain other expenses, through a program referred to
as the Paycheck Protection Program (“PPP”). Subsequent legislation provided additional
funding for the PPP and extended its duration. Businesses and eligible individuals could |
apply for PPP loans through May 31, 2021.

4. To obtain a PPP loan, a qualifying business, independent contractor/self-
employed individual, or sole proprietorship was required to submit a PPP loan application
signed by an authorized representative of the business. The PPP loan application required
the applicant (through its authorized representative) to acknowledge the program rules and
make certain affirmative certifications to be eligible to obtain the PPP loan. The PPP loan
application also required the applicant (through its authorized representative) to state,
among other things, its: (a) average monthly payroll expenses; and (b) number of
employees. (Applicants who did not have employees and who filed an IRS Form 1040,
Schedule C could report gross income instead of payroll.) These figures were used to
calculate the loan amount the applicant was eligible to receive under the PPP. In addition,
businesses or sole proprietorships applying for a PPP loan were required to provide
documentation showing their eligibility and qualifying payroll amount.

5. A participating financial institution (the lender) processed a PPP loan

application. If the lender approved a PPP loan application, it funded the PPP loan using its
Case 2:26-cr-00107-JAD-NJK Document1 Filed 06/10/26 Page4of/7

own monies, which the Small Business Administration (“SBA”) guaranteed 100%. If the
lender made a PPP loan to the applicant, the SBA paid the lender a processing fee, which
was calculated based on the amount of the loan. The lender transmitted information to the
SBA while processing the loan data from the application, including information about the
borrower, the total amount of the loan, and the listed number of employees. The SBA
oversaw the PPP and had authority over all loans. Over 5,000 lending institutions, mostly
banks and credit unions, participated in the PPP.

6. The business or individual receiving the PPP loan proceeds had to spend the
funds on certain permissible expenses, such as payroll costs, interest on mortgages, rent, and
utilities. The PPP allowed the interest and principal on the PPP loan to be entirely forgiven
if the loan proceeds were spent on permissible expense items within a designated period of
time and used a specified portion of the PPP loan proceeds on payroll expenses. When a

PPP loan was forgiven, the SBA paid the lender the amount of the forgiven interest and

principal.
COUNTS ONE AND TWO
Wire Fraud
(18 U.S.C § 1343)
7. Paragraphs 1-6 of this Indictment are incorporated herein as if set forth in full.

8. From on or about April 2, 2021, to on or about October 29, 2021, within the
State and Federal District of Nevada and elsewhere,
JAMES SEAN FREEMAN, I,
defendant herein, devised, intended to devise, and participated in a scheme and artifice to
defraud the SBA and Harvest and to obtain money and property by means of materially

false and fraudulent pretenses, representations, and promises.
Case 2:26-cr-00107-JAD-NJK Document1 Filed 06/10/26 Page5of7

Purpose of the Scheme to Defraud

9. The purpose of the scheme was for Freeman to unjustly enrich himself by
fraudulently obtaining PPP loan proceeds by means of false and fraudulent pretenses,
representations, and promises.

Manner and Means of the Scheme to Defraud

10. ‘It was part of the scheme that Freeman electronically submitted applications
for two PPP loans to Harvest containing materially false and fraudulent information, as
more fully described below.

11. On or about April 2, 2021, Freeman submitted to Harvest the first PPP loan
application containing materially false information, including but not limited to false
information that he was the sole proprietor of a company that did not exist and false
information regarding the revenue purportedly received by the non-existent company.

12. Freeman also provided fake documentation to support this PPP loan
application, that is, a false Schedule C for tax year 2019 that was neither filed nor intended
to be filed with the IRS.

13. | Onor about April 9, 2021, after Freeman’s PPP loan was approved, Harvest
electronically deposited $16,940 in PPP loan funds into Freeman’s Navy Federal Credit
Union account ending in X-2992 (“the X-2992 account”) in Las Vegas, Nevada.

14. On or about April 10, 2021, Freeman submitted to Harvest a second PPP loan
application for the same non-existent company containing materially false and fraudulent
information, including but not limited to false information that he was the sole proprietor of
the non-existent company and false information regarding the revenue purportedly received

by the non-existent company.
Case 2:26-cr-00107-JAD-NJK Document1 Filed 06/10/26 Page 6of/7

15. | Freeman again provided fake documentation to support this second PPP loan

application, that is, a false Schedule C for tax year 2019 that was neither filed nor intended

to be filed with the IRS.
16. Onor about April 26, 2021, after Freeman’ second PPP loan was approved,
Harvest electronically deposited $16,940 in PPP loan funds into the X-2992 account.

17. On or about October 26, 2021, Freeman electronically submitted a PPP loan
forgiveness application for the first PPP loan, which was approved. On or about October 29,
2021, the SBA paid the principal loan amount of $16,940 plus interest to Harvest.

18. Onor about October 26, 2021, Freeman electronically submitted a PPP loan
forgiveness application for the second PPP loan, which was approved. On or about October
29, 2021, the SBA paid the principal loan amount of $16,940 plus interest to Harvest.

The Wires

19. COUNT ONE: On or about April 2, 2021, for the purpose of executing the
scheme and artifice to defraud, Freeman caused to be transmitted by means of wire
communication in interstate commerce the signals and sounds associated with the transfer
of $16,940 in PPP loan funds from Harvest outside of Nevada into the X-2992 account in
Nevada.

20. COUNT TWO: On or about April 10, 2021, for the purpose of executing the
scheme and artifice to defraud, Freeman caused to be transmitted by means of wire
communication in interstate commerce the signals and sounds associated with the transfer
of $16,940 in PPP loan funds from Harvest outside of Nevada into the X-2992 account in
Nevada.

///

///
Case 2:26-cr-00107-JAD-NJK Document1 Filed 06/10/26 Page/7of7

21. | Each wire communication constituting a separate violation of Title 18, United
States Code, Section 1343.

DATED: This 10" day of June 2026.

A TRUE BILL:

/S/
FOREPERSON OF THE GRAND JURY

TODD BLANCHE
Acting Attorney General

IMBERLY M. FRA
Assistant United States Attorney

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