Indictment — United States v. Timothy Craig Jolloff and Lisa Ann Jolloff, Middle District of Florida

Summary

A grand jury Indictment against Timothy Craig Jolloff and Lisa Ann Jolloff in the U.S. District Court for the Middle District of Florida, Fort Myers Division, filed July 12, 2023 as Document 27 in No. 2:23-cr-00079-TPB-NPM. Its caption lists 18 U.S.C. §§ 1343, 1344, 1956(h), 1957, and Counts One through Twelve charge wire fraud. It alleges that false EIDL and PPP applications submitted to the SBA, Lender 1 and Lender 2 in the names of Indiana and Florida companies led to approval of at least 11 EIDL applications, 7 First Draw PPP loan applications and 1 Second Draw PPP loan application. It alleges approximately $3,403,265 was deposited into accounts the defendants controlled and used for residences, a 2019 GMC Sierra truck, pontoon boats and businesses. The forfeiture allegation seeks an order of approximately $3,403,265.

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Case 2:23-cr-00079-TPB-NPM Document 27 Filed 07/12/23 Page 1 of 23 PagelD 69

UNITED STATES DISTRICT COURT
MIDDLE DISTRICT OF FLORIDA
FORT MYERS DIVISION

UNITED STATES OF AMERICA

v. CASE NO. 2:23-r-4-T0B N yy!

TIMOTHY CRAIG JOLLOFF and 18 U.S.C. § 1343
LISA ANN JOLLOFF 18 U.S.C. § 1344
18 U.S.C. § 1956(h)
18 U.S.C. § 1957

INDICTMENT

The Grand Jury charges:

COUNTS ONE THROUGH TWELVE
(Wire Fraud)

A. Introduction

At all times material to this Indictment:

l. TIMOTHY CRAIG JOLLOFF was a resident of the Middle
District of Florida (“MDFL”) and the Northern District of Indiana (“NDIN”)
and was married to LISA ANN JOLLOFF (collectively, “the JOLLOFFS”).
Together with his wife, TIMOTHY CRAIG JOLLOFF purported to own and
operate Central Acquisitions, Inc., FXFWY01, Inc., FKFWY03, Inc.,
FXFWY04, Inc., FXKOKO1, Inc., FXKOKO2, Inc., J.P. Ganczak
Enterprises, Inc., MRK Delivery, Inc., and Schultise Enterprises, Inc., which

were all Indiana corporations. The JOLLOFFS also purported to own and
Case 2:23-cr-00079-TPB-NPM Document 27 Filed 07/12/23 Page 2 of 23 PagelD 70

operate Avisal, Inc., MSN Delivery’s, Inc., and TZ International, Inc., which
were all Florida corporations.

2. 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 businesses and by assisting in the economic recovery of
communities after disasters.

The Paycheck Protection Program

3. The Coronavirus Aid, Relief, and Economic Security
(“CARES”) Act was 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
forgivable loans to small businesses for job retention and certain other
expenses, through a program referred to as the Paycheck Protection Program
(“PPP”).

4. 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
Case 2:23-cr-00079-TPB-NPM Document 27 Filed 07/12/23 Page 3 of 23 PagelD 71

(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 (SBA Form 2483), the small business
(through its authorized representative) 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
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. Individuals who operated under a sole proprietorship
or as an independent contractor or eligible self-employment individual were
also eligible to apply for a PPP loan.

5. PPP loan applications were processed by a participating lender. If
a PPP loan application was approved, the participating lender funded the PPP
loan using its own monies, which were 100% guaranteed by the SBA. Data
from the application, including information from the borrower, the total
amount of the loan, and the listed number of employees, was transmitted by
the lender to the SBA in the course of processing the loan.

6. 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
Case 2:23-cr-00079-TPB-NPM Document 27 Filed 07/12/23 Page 4 of 23 PagelD 72

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.

7. The Economic Aid to Hard-Hit Small Business, Nonprofits and
Venues Act (“Economic Aid Act”) was a federal law enacted in or around
December 2020. The Economic Aid Act authorized the SBA to guarantee
Second Draw PPP loans under generally the same terms and conditions
available under the original PPP (“First Draw PPP Loans”). Only First Draw
PPP Loan borrowers who had used, or will have used, the full amount of the
First Draw PPP Loan on or before the expected date on which the Second
Draw PPP Loan was disbursed could receive a Second Draw PPP loan.
Further, a borrower would be eligible for a Second Draw PPP loan only if it
had 300 or fewer employees and experienced a revenue reduction of 25% or
greater in 2020 relative to 2019. Second Draw PPP loan applicants were also
required to make the same or similar certifications and representations
concerning the use of PPP funds.

The Economic Injury Disaster Relief Program

8. The Economic Injury Disaster Loan (“EIDL”) program was an
SBA program that provided low-interest financing to small businesses, renters,

and homeowners in regions affected by declared disasters.
Case 2:23-cr-00079-TPB-NPM Document 27 Filed 07/12/23 Page 5 of 23 PagelD 73

9. The CARES Act authorized the SBA to provide EIDLs of up to
$2 million to eligible small businesses experiencing substantial financial
disruption due to the COVID-19 pandemic. In addition, the CARES Act
authorized the SBA to issue advances of up to $10,000 to small businesses
within three days of applying for an EIDL. The amount of the advance was
determined by the number of employees the applicant certified having. The
advances did not have to be repaid.

10. To obtain an EIDL and advance, a qualifying business had to
submit an application to the SBA and provide information about its operation,
such as the number of employees, gross revenues for the 12-month period
preceding the disaster, and cost of goods sold in the 12-month period
preceding the disaster. In the case of EIDLs for COVID-19 relief, the 12-
month period was that preceding January 31, 2020. For EIDL applications
submitted before May 4, 2020, an EIDL applicant was required to disclose
whether the applicant had been convicted of a criminal offense. The applicant
also had to certify that all the information in the application was true and
correct to the best of the applicant’s knowledge.

11. EIDL applications were submitted directly to the SBA. The
amount of the loan, if the application was approved, was determined based, in

part, on the information provided by the applicant about employment,
Case 2:23-cr-00079-TPB-NPM Document 27 Filed 07/12/23 Page 6 of 23 PagelD 74

revenue, and cost of goods, as described above. Any funds issued under an
EIDL or advance were issued directly by the SBA. EIDL funds could be used
for payroll expenses, sick leave, production costs, and business obligations,
such as debts, rents, and mortgage payments. If the applicant also obtained a
loan under the PPP, the EIDL funds could not be used for the same purpose
as the PPP funds.

PPP Lenders

12. Lender 1 was a federally-insured financial institution that was
insured by the FDIC and based in Cleveland, Ohio. Lender 1 participated in
the SBA’s PPP as a lender and was authorized to lend funds to eligible
borrowers under the terms of the PPP. The JOLLOFFS also maintained and
controlled bank accounts at Lender 1.

13. Lender 2 was a federally-insured financial institution that was
insured by the FDIC and based in Wilmington, North Carolina. Lender 2
participated in the SBA’s PPP as a lender and was authorized to lend funds to
eligible borrowers under the terms of the PPP.

Bank Accounts Controlled by the Defendants

14. Bank 1 was a federally-insured financial institutions that was
insured by the FDIC.

15. The JOLLOFFS, individually and together, controlled and
Case 2:23-cr-00079-TPB-NPM Document 27 Filed 07/12/23 Page 7 of 23 PagelD 75

maintained the following financial accounts:

a. A checking account ending in -0919 at Bank 1 in the name
of “FXKOK02 Inc” (“Bank 1 account ending in -0919”), with the JOLLOFFS
as the sole signatories.

b. A checking account ending in -0893 at Bank 1 in the name
of “FXFWY04 Inc” (“Bank 1 account ending in -0893”), with the JOLLOFFS
as the sole signatories.

c. A checking account ending in -0877 at Bank 1 in the
name of “MRK Delivery Inc” (“Bank 1 account ending in -0877”), with the
JOLLOFFS as the sole signatories.

d. A checking account ending in -5470 at Lender 1 in the
name of “Avisal Inc.” (“Lender 1 account ending in -5470”), with the
JOLLOFFS as the sole signatories.

e. A checking account ending in -5397 at Lender 1 in the
name of “Central Acquisition, Inc.” (“Lender 1 account ending in -5397”),
with the JOLLOFFS as the sole signatories.

f. A checking account ending in -5389 at Lender 1 in the
name of “FXFWY0O1, Inc.” (“Lender 1 account ending in -5389”), with the
JOLLOFFS as the sole signatories.

g. A checking account ending in -5462 at Lender I in the
Case 2:23-cr-00079-TPB-NPM Document 27 Filed 07/12/23 Page 8 of 23 PagelD 76

name of “FXFWY03, Inc.” (“Lender 1 account ending in -5462”), with the
JOLLOFFS as the sole signatories.

h. | Achecking account ending in -5405 at Lender 1 in the
name of “FXFWY04, Inc.” (“Lender 1 account ending in -5405”), with the
JOLLOFFS as the sole signatories.

i. A checking account ending in -5447 at Lender 1 in the
name of “FXKOKO1, Inc.” (“Lender 1 account ending in -5447”), with the
JOLLOFFS as the sole signatories.

j. A checking account ending in -5413 at Lender 1 in the
name of “FXKOK02, Inc.” (“Lender 1 account ending in -5413”), with the
JOLLOFFS as the sole signatories.

k. A checking account ending in -5439 at Lender 1 in the
name of “J.P. Ganczak Enterprises, Inc.” (“Lender 1 account ending in -
5439”), with the JOLLOFFS as the sole signatories.

1. A checking account ending in -5454 at Lender 1 in the
name of “MRK Delivery Inc.” (“Lender 1 account ending in -5454”), with the
JOLLOFFS as the sole signatories.

m. A checking account ending in -5496 at Lender 1 in the
name of “MSN Deliverys Inc.” (“Lender 1 account ending in -5496”), with

the JOLLOFFS as the sole signatories.
Case 2:23-cr-00079-TPB-NPM Document 27 Filed 07/12/23 Page 9 of 23 PagelD 77

n. A checking account ending in -5421 at Lender 1 in the
name of “Schultise Enterprises, Inc.” (“Lender 1 account ending in -5421”),
with the JOLLOFFS as the sole signatories.

o. | Achecking account ending in -5355 at Lender 1 in the
name of “TZ International Inc” (“Lender 1 account ending in -5355”), with
the JOLLOFFS as the sole signatories.

B. The Scheme and Artifice
16. Beginning on an unknown date, but no later than in or around
April 2020, and continuing through the present, in the Middle District of
Florida and elsewhere, the defendants,

TIMOTHY CRAIG JOLLOFF and
LISA ANN JOLLOFF,

knowingly devised and intended 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.
C. Manner and Means of the Scheme and Artifice
17. The manner and means by which the JOLLOFFS sought to
accomplish the scheme and artifice to defraud included, among others, the
following:
a. It was part of the scheme and artifice to defraud that the

JOLLOFFS would and did engage in a scheme to obtain money from the SBA
Case 2:23-cr-00079-TPB-NPM Document 27 Filed 07/12/23 Page 10 of 23 PagelD 78

and PPP lenders by submitting false and fraudulent EIDL and PPP loan
applications and certifications to the SBA, Lender 1, and Lender 2 in the
names of various businesses that purported to be owned and controlled by the
JOLLOFFS.

b. It was further part of the scheme and artifice to defraud
that TIMOTHY CRAIG JOLLOFF would and did make and cause to be
made materially false and fraudulent statements to the SBA in EIDL
applications and loan documents, including false and fraudulent
representations regarding the applicant’s ownership interest, number of
persons employed by the loan applicant, the applicant’s gross revenues and
cost of goods sold, as well as misrepresentations about the applicant’s use of
EIDL funds.

c. It was further part of the scheme and artifice to defraud
that the JOLLOFFS would and did make and cause to be made materially
false and fraudulent statements to Lender 1 and Lender 2 in First and Second
Draw PPP loan applications, including false and fraudulent representations
regarding the applicant’s average monthly payroll and the number of persons
employed by the loan applicant.

d. It was further part of the scheme and artifice to defraud

that the JOLLOFFS would and did submit and cause the submission of

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materially false and fictitious documents to Lender 1 and Lender 2 in support
of the JOLLOFFS’ First and Second Draw PPP loan applications, including
false payroll documents, tax documents, and other corporate financial
documents.

e. It was further part of the scheme and artifice to defraud
that the JOLLOFFS would and did falsely and fraudulently certify that the
PPP funds acquired from the requested First and Second Draw PPP loans
would be used to retain workers, maintain payroll, or make mortgage interest
payments, lease payments, and utility payments on behalf of the applicants.

f. It was further part of the scheme and artifice to defraud
that LISA ANN JOLLOFF would and did falsely and fraudulently certify that
First Draw PPP loan funds were only used for eligible expenses.

g. It was further part of the scheme and artifice to defraud
that the JOLLOFFS’ materially false, fraudulent, and misleading
representations would and did cause the SBA, Lender 1, and Lender 2 to
approve at least 11 EIDL applications, 7 First Draw PPP loan applications,
and 1 Second Draw PPP loan application, resulting in the SBA, Lender 1, and
Lender 2 depositing approximately $3,403,265 in EIDL, EIDL Advance, and
PPP funds into accounts controlled by the JOLLOFFS.

h. It was further part of the scheme and artifice to defraud

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that the JOLLOFFS would and did use and cause EIDL and PPP funds to be
used for unauthorized purposes and for their own personal enrichment,
including the purchase of residences in Fort Myers, Florida and Indiana, a
2019 GMC Sierra truck, pontoon boats, a landscape and furniture business,
and to make personal credit card payments.

i. It was further part of the scheme and artifice to defraud
that the JOLLOFFS would and did misrepresent, hide, and conceal, and
cause to be misrepresented, hidden and concealed, the purpose of the acts
performed in furtherance of the scheme to defraud.

D. Execution of the Scheme and Artifice
18. Onor about the dates set forth below, in the Middle District of
Florida and elsewhere, the defendants,

TIMOTHY CRAIG JOLLOFF and
LISA ANN JOLLOFF,

for the purpose of executing the scheme and artifice described above,
transmitted and caused to be transmitted by means of wire communication in
interstate and foreign commerce the writings, signs, signals, pictures, and

sounds described below, each transmission constituting a separate count:

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COUNT | DEFENDANT | DATE OF INTERSTATE WIRE
: WIRE TRANSMISSION
ONE TIMOTHY | April 4, 2020 | Electronic transmission of
CRAIG fraudulent EIDL application in
JOLLOFF the name of Avisal, Inc. from
the MDFL to the SBA’s servers
located outside the State of
Florida.
TWO TIMOTHY | April 4, 2020 | Electronic transmission of
CRAIG fraudulent EIDL application in
JOLLOFF the name of MRK Delivery, Inc.
from the MDFL to the SBA’s
servers located outside the State
of Florida.
THREE TIMOTHY | April 4, 2020 | Electronic transmission of
CRAIG fraudulent EIDL application in
JOLLOFF the name of FXFWYO03, Inc.
from the MDFL to the SBA’s
servers located outside the State
of Florida.
FOUR TIMOTHY | April 4, 2020 | Electronic transmission of
CRAIG fraudulent EIDL application in
JOLLOFF the name of Schultise
Enterprises, Inc. from the
MDEFTL to the SBA’s servers
located outside the State of
Florida.
FIVE TIMOTHY | April 4, 2020 | Electronic transmission of
CRAIG fraudulent EIDL application in
JOLLOFF the name of FXKOKO1, Inc.
from the MDFL to the SBA’s
servers located outside the State
of Florida.
SIX TIMOTHY | April 4, 2020 | Electronic transmission of
CRAIG fraudulent EIDL application in
JOLLOFF the name of Central
Acquisitions, Inc. from the
MDEFL to the SBA’s servers
located outside the State of
Florida.

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SEVEN

TIMOTHY
CRAIG
JOLLOFF

April 4, 2020

Electronic transmission of
fraudulent EIDL application in
the name of FXFWY01, Inc.
from the MDFL to the SBA’s
servers located outside the State
of Florida.

EIGHT

TIMOTHY
CRAIG
JOLLOFF

April 4, 2020

Electronic transmission of
fraudulent EIDL application in
the name of FXFWY04, Inc.
from the MDFL to the SBA’s
servers located outside the State
of Florida.

TIMOTHY
CRAIG
JOLLOFF

April 4, 2020

Electronic transmission of
fraudulent EIDL application in
the name of FXKOKO0O2, Inc.
from the MDFL to the SBA’s
servers located outside the State
of Florida.

TEN

TIMOTHY
CRAIG
JOLLOFF

April 4, 2020

Electronic transmission of
fraudulent EIDL application in
the name of TZ International,
Inc. from the MDFL to the
SBA’s servers located outside
the State of Florida.

ELEVEN

TIMOTHY
CRAIG
JOLLOFF

April 4, 2020

Electronic transmission of
fraudulent EIDL application in
the name of JP Ganczak
Enterprises, Inc. from the
MDEFL to the SBA’s servers
located outside the State of
Florida.

TWELVE

LISA ANN
JOLLOFF

March 10,
2021

Electronic transmission of a
fraudulent Second Draw PPP
application in the name of
FXFWYOl1, Inc. from the
MDEFL to Lender 2’s servers
located outside the State of
Florida.

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In violation of 18 U.S.C. §§ 1343 and 2.

COUNTS THIRTEEN THROUGH NINETEEN
(Bank Fraud)

A. Introduction
1. The Grand Jury hereby realleges paragraphs 1 through 15a-150
of Counts One through Twelve of this Indictment and incorporates such
paragraphs by this reference as though fully set forth herein.
B. The Scheme and Artifice
2. Beginning on an unknown date, but no later than in or around
April 2020, and continuing through the present, in the Middle District of
Florida and elsewhere, the defendant,
TIMOTHY CRAIG JOLLOFF,
did knowingly and intentionally execute, and attempt to execute, a scheme
and artifice to defraud a financial institution, and to obtain monies, funds,
credits, assets, and other property owned by, and under the custody and
control of, a financial institution, by means of materially false and fraudulent
pretenses, representations, and promises.
C. Manner and Means of the Scheme
3. The manner and means of the scheme and artifice are set forth in
Paragraphs 17a, 17c — 17e, and 17g — 17i, of Counts One through Twelve of

this Indictment, the allegations of which are realleged and incorporated by

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reference as if fully set forth herein.

D. Execution of the Scheme

4. On or about the dates set forth below, in the Middle District of

Florida and elsewhere, the defendant,

TIMOTHY CRAIG JOLLOFF,
knowingly and with intent to defraud executed and attempted to execute the
scheme and artifice to defraud a financial institution whose deposits were
insured by the FDIC, as described above, and knowingly and with intent to
defraud executed and attempted to execute the scheme and artifice to obtain
moneys, funds, credits, assets, securities and other property owned by and
under the custody and control of a financial institution whose deposits were
insured by the FDIC, by means of materially false and fraudulent pretenses,
representations, and promises, as described above, in that TIMOTHY CRAIG
JOLLOFF caused, and attempted to cause, the following PPP loans to be

made:

COUNT | DATE Z EXECUTION

THIR ; TEEN April 4, 2020 $890,900 First Draw PPP loan from Lender
1 in the name of J.P. Ganczak Enterprises,
Inc.

FOURTEEN | May 4, 2020 | $39,013 First Draw PPP loan from Lender 2
in the name of FXFWY01, Inc.

FIFTEEN May 4, 2020 | $37,825 First Draw PPP loan from Lender 2
in the name of FXFWY03, Inc.

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SIXTEEN May 4, 2020 | $93,863 First Draw PPP loan from Lender 2
in the name of FXKFWY04, Inc.

SEVENTEEN | May 4, 2020 | $58,868 First Draw PPP loan from Lender 2
in the name of FKKOK02, Inc.

EIGHTEEN May 4, 2020 | $96,262 First Draw PPP loan from Lender 2
in the name of Schultise Enterprises, Inc.

NINETEEN May 5, 2020 | $84,445 First Draw PPP loan from Lender 2
in the name of MRK Delivery, Inc.

In violation of 18 U.S.C. §§ 1344 and 2.

COUNT TWENTY
(Conspiracy to Commit Money Laundering)

A. Introduction

1. The Grand Jury hereby realleges Paragraphs 1 through 15a-150
of Counts One through Twelve of this Indictment and incorporates such
paragraphs by this reference as though fully set forth herein.

B. The Conspiracy

2. Beginning on an unknown date, but no later than in or around
April 2020, and continuing through the present, in the Middle District of
Florida and elsewhere, the defendants,

TIMOTHY CRAIG JOLLOFF and
LISA ANN JOLLOFF,

did knowingly combine, conspire, and agree with each other and other

persons known and unknown to the Grand Jury to commit certain offenses

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against the United States, in violation of 18 U.S.C. § 1957, to wit: to
knowingly engage and attempt to engage in monetary transactions in and
affecting interstate and foreign commerce, in criminally derived property of a
value greater than $10,000.00, which property was, in fact, derived from a
specified unlawful activity, namely, wire fraud, in violation of 18 U.S.C.
§ 1343, and bank fraud, in violation of 18 U.S.C. § 1344.
C. Manner and Means

3. The Grand Jury realleges Paragraphs 17a — 171 of Counts One
through Twelve of this Indictment and incorporates such paragraphs by this
reference as though fully set forth herein.

All in violation of 18 U.S.C. § 1956(h).

COUNTS TWENTY-ONE THROUGH TWENTY-FOUR
(Illegal Monetary Transactions)

A. Introduction
1. The Grand Jury hereby realleges Paragraphs 1 through 15a-150
and 17a — 17i of Counts One through Twelve of this Indictment and
incorporates such paragraphs by this reference as though fully set forth herein.
B. Offense
2. On or about the dates listed below, in the Middle District of

Florida and elsewhere, the defendants,

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TIMOTHY CRAIG JOLLOFF and
LISA ANN JOLLOFF,

did knowingly engage and attempt to engage in the monetary transactions
described below, and aided and abetted each other and others in engaging in
the monetary transactions described below, in and affecting interstate and
foreign commerce, in criminally derived property of a value greater than
$10,000.00, which property was, in fact, derived from a specified unlawful
activity, namely, wire fraud, in violation of 18 U.S.C. § 1343 and bank fraud,

in violation of 18 U.S.C. § 1344, specifically:

COUNT — DATE | MONETARY TRANSACTION

$56,355.66 check from the Lender 1
account ending in -5470 issued to
TWENTY-ONE | May 19, 2020 | sam Galloway Ford or an individual
with the initials K.S. for the purchase
of a 2019 GMC Sierra truck.

$71,764 wire transfer from the
Lender 1 account ending in -5355 to
TWENTY-TWO June 3, 2020 | 4 realty and title company for the
purchase of a residence in Fort
Myers, Florida.

$114,900 wire transfer from the
Lender 1 account ending in -5496 to
TWENTY-THREE | July 7, 2020 | 4 boat seller for the purchase of a
2018 Crest 270 Continental pontoon
boat.

$325,724.61 wire transfer from the
Lender 1 account ending in -5496 to
TWENTY-FOUR | October 5, 2020 | @ Jaw firm in Naples, Florida for the
purchase of a lawn care and
landscape company.

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In violation of 18 U.S.C. §§ 1957 and 2.
FORFEITURE

1, The allegations contained in Counts One through Twenty-Four,
are incorporated by reference for the purpose of alleging forfeiture pursuant to
18 U.S.C. §§ 981(a)(1)(C), 982(a)(1), 982(a)(2)(A), and 28 U.S.C. § 2461(c).

2. Upon conviction of a violation of 18 U.S.C. § 1343, the
defendants,

TIMOTHY CRAIG JOLLOFF and
LISA ANN JOLLOFF,

shall forfeit to the United States, pursuant to 18 U.S.C. § 981(a)(1)(C) and 28
U.S.C. § 2461(c), any property, real or personal, which constitutes or is
derived from proceeds traceable to the violation.

3. Upon conviction of a violation of 18 U.S.C. § 1344, the
defendants,

TIMOTHY CRAIG JOLLOFF and
LISA ANN JOLLOFF,

shall forfeit to the United States, pursuant to 18 U.S.C. § 982(a)(2)(A), any
property, real or personal, which constitutes or is derived from proceeds
traceable to the violation.

4, Upon conviction of a violation of 18 U.S.C. §§ 1956(h) and/or

1957, the defendants,

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TIMOTHY CRAIG JOLLOFF and
LISA ANN JOLLOFF,

shall forfeit to the United States, pursuant to 18 U.S.C. § 982(a)(1), any
property, real or personal, involved in such offense, or any property traceable
to such property.

5. The property to be forfeited includes, but is not limited to, an
order of forfeiture in the amount of approximately $3,403,265, which
represents the proceeds obtained from the offenses as well as the amount
involved in the offenses, as well as a 2019 GMC truck with Vehicle
Identification Number 1GTU9FEL9KZ402935, which was purchased with
proceeds obtained from the offenses.

6. If any of the property 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
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,

21
Case 2:23-cr-00079-TPB-NPM Document 27 Filed 07/12/23 Page 22 of 23 PagelD 90

the United States shall be entitled to forfeiture of substitute property under the
provisions of 21 U.S.C. § 853(p), as incorporated by 18 U.S.C. § 982(b)(1) and

28 U.S.C. § 2461(c).

oreperson

ROGER B. HANDBERG
United States Attorney

Trenton J. Reichling—
Assistant United States Attorney

a

Christopher F,. Murr Peg

Assistant United States Attorney
Chief, Criminal Division (South)

22
FORM OBD-34
APR 1991

Case 2:23-cr-00079-TPB-NPM Document 27 Filed 07/12/23 Page 23 of 23 PagelD 91
No. 2:23-cr-

UNITED STATES DISTRICT COURT
Middle District of Florida
Fort Myers Division

THE UNITED STATES OF AMERICA

VS.

TIMOTHY CRAIG JOLLOFF and
LISA ANN JOLLOFF

INDICTMENT
Violations:

18 U.S.C. §§ 1343, 1344, 1956(h), 1957

Filed in open court this 12" day

Of July, 2023.

Clerk

Bail $

GPO 863 525


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