Indictment — United States v. David Starling and Benjamin Young, District of Oregon (Document 1)
Summary
A grand jury indictment against David Starling and Benjamin Young in the United States District Court for the District of Oregon, Portland Division, Case 3:26-cr-00205-AN, filed June 9, 2026 as Document 1. Count 1 charges conspiracy to defraud the United States under 18 U.S.C. § 371, alleging that from 2020 through at least in or about October 2021 the conspirators fabricated wages paid to purported employees of businesses they controlled to obtain COVID-Related Tax Credits and to defraud the SBA in the Paycheck Protection Program and Preferred Lender/7(a) Program. It states that Young applied for PPP loans for a Utah non-profit employer, funded for $852,115 and $843,595. Counts 2-13 charge wire fraud under 18 U.S.C. § 1343, including PPP forgiveness applications, and a forfeiture allegation follows.
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“Indictment — United States v. David Starling and Benjamin Young, District of Oregon (Document 1).”
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Case 3:26-cr-00205-AN Document 1 Filed 06/09/26 Page 1 of 20
UNITED STATES DISTRICT COURT
DISTRICT OF OREGON
PORTLAND DIVISION
UNITED STATES OF AMERICA 3: 26-cr-00205-SI
v. INDICTMENT
DAVID STARLING and 18 u.s.c. §§ 371, 1343
BENJAMIN YOUNG,
Forfeiture Allegation
Defendants.
THE GRAND JURY CHARGES:
INTRODUCTION
At all times relevant to this Indictment, unless otherwise indicated:
A. The Defendants and Relevant Entities, Individuals, and Bank Accounts
1. Defendant DAVID STARLING ("STARLING") resided in Provo, Utah.
STARLING was a tax preparer who was also an Enrolled Agent for the Internal Revenue Service
("IRS"). STARLING owned or controlled the following entities:
A) Gladys' Multiservices, LLC ("Gladys' Multiservices"), which is an entity doing
business as Tax Pro of Provo ("Tax Pro"). In 2019, Gladys' Multiservices
reported 4 employees to the IRS, to which it paid $29,187 in gross wages.
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B) Star Property Holdings of Utah, LLC ("Star Property Holdings"). In 2019, Star
Prope1ty Holdings reported zero employees to the IRS, to which it paid $0 in
gross wages.
C) Immigration Solutions, I LC ("Immigration Solutions"). In 2019, Immigration
Solutions reported zero employees to the IRS, to whicl1 it paid $0 in gross wages.
2. STARLING was a joint owner of Utah Community Credit Union account ending
in 6800.
3. Defendant BENJAMIN YOUNG ("YOUNG") resided in Provo, Utah. YOUNG
was STARLINU's son-in-law and owned or controlled the following entities:
A) Square the Books, LLC ("Square the Books"). Jn 2019, Square the Books
reported 2 employees to the IRS, to which it paid $4,000 in gross wages.
B) Young Propcriics, ILC ("Young Properties"). In 2019, Young Properties
reported 0 employees to the IRS, to which it paid $0 in gross wages.
4. YOUNG was a Certified Public Accountant and employed full-time as the
Financial Manager of a Utah non-profit organization ("VNPO"), located in a commercial
building in Provo, Utah.
5. As VNPO's Financial Manager, YOUNG had control over and signatory
authority on VNPO's Bonneville Bank accounts ending in 7121 and 2217.
6. YOUNG applied for two Paycheck Protection Program Loans on VNPO's behalf:
A) On or about August 12, 2020, the SBA funded loan 54334482-09 for $852,115
into VNPO' s Bonneville account ending in 7121.
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B) On or about February 10, 2021, the SBA funded loan 58988884-08 for $843,595
into VNPO's Bonneville account ending in 2217.
7. YOUNG was a joint owner with his wife of a personal account at USAA Bank
ending in 6559.
8. On or about January 21, 2021, YOUNG opened an investment brokerage account
ending in 1713 on behalf ofVNPO at TD Ameritrade. While YOUNG was authorized to open
this account by his employer, YOUNG had sole authority over all funds in this account.
9. On or about February 17, 2021, YOUNG opened a personal investment brokerage
account ending in 6098 at TD Ameritrade. YOUNG had sole authority over all funds in this
account.
10. Co-Conspirator 1, an individual whose identity is known to the Grand Jmy,
resided in Sherwood, Oregon. Co-Conspirator 1 is STARLING's brother. Co-Conspirator 1
owned or controlled the following entities:
A) Starling CPA, LLC ("Starling CPA"), which is an entity located in Sherwood,
Oregon. In 2019, Starling CPA reported 0 employees to the IRS, to which it paid
$0 in gross wages.
B) Kaitlyn's Cases. In 2019, Kaitlyn's Cases reported Oemployees to the IRS, to
which it paid $0 in gross wages.
11. Co-Conspirator 1 and STARLING owned or controlled Lake Oswego Property
Management, LLC ("L.O. Property Management"), which is an entity located in Lake Oswego,
.Oregon. In 2019, L. 0. Property Management reported Oemployees to the IRS, to which it paid
$0 in gross wages.
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12. The IRS was an agency of the United States Department of the Treasury
responsible for administering and enforcing federal tax laws of the United States, including
refundable tax credits, and collecting taxes owed to the United States.
13. Federal law required employers to collect, truthfully account for, and pay over to
the United States certain payroll taxes, including their employees' withheld federal income taxes,
Social Security and Medicare taxes, and the employer's matching portion of the Social Security
and Medicare taxes. A responsible person at a business was required to file, quarterly, an
Employer's Quarterly Federal Tax Return, Form 941 ("Form 941"), reporting certain
info1mation and assessing payroll taxes for the business and reporting certain information,
including the number of employees working at the business and the wages paid by the business.
14. A Wage and Tax Statement, Fonn W-2 ("Fonn W-2"), reported wages paid by an
employer to an employee and taxes withheld from those wages. It was issued by United States
employers to employees and filed by employers with the Social Security Administration.
15. The 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.
16. A tax return was a filing with the IRS which detailed the tax obligations of the
taxpayer or organization. Tax returns in the United States included, among others, Form 941 and
Form 1040.
II I
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B. COVID-19 Disaster Loans and Programs
17. On March 27, 2020, President Trump signed the Coronavirus Aid, Relief, and
Economic Security ("CARES") Act into law.
18. The CARES Act provided for an employee retention credit ("ERC"), a refundable
tax credit created to encourage employers to retain and pay employees during the COVID-19
pandemic. The Taxpayer Certainty and Disaster Tax Relief Act of2020 and the American
Rescue Plan Act ("ARP A") modified and extended the ERC.
19. Eligible employers under the ERC were those who incurred a suspension of
operation due to COVID-19 or a decline in gross receipts.
a. Qualified Sick and l◄'amily Leave
20. The Qualified Sick and Family Leave Credits ("SFLC") and Qualified Family
Leave Credit ("QFLC") were refundable tax credits introduced under the Pan1ilies First
Coronavirus Response Act ("FFCRA") to reimburse employers for providing paid sick and
family leave to employees aJTected by COVTD-19. These credits were designed to support
employees who were unable to work due to quarantine, illness, or caregiving responsibilities
related to COVID-19.
21. The ERC, SFLC and QF LC credits ("COVI D-19 Related Tax Credits") were
administered by the IRS and were available to employers only in 2020 and 2021. The programs
allowed refundable credits equal to a percentage of an employee's pay, subject to aggregate caps.
22. An employer could claim COVID-19 Related Tax Credits by filing a Form 941
with the IRS for the relevant quruier. The Form 941 required an employer to provide the IRS
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info1mation about the number of employees the business had and the wages paid by the business
to employees during that quarter.
b. Paycheck Protection Program
23. The CARES Act also created the Paycheck Protection Program ("PPP"), which
authorized the SBA to guarantee loans ofup to $10,000,000 to qualifying employers without
collateral or personal guarantees from the borrowers. The Act required lenders making loans
under the PPP to defer all repayment obligations for not less than six months on such loans and
required borrowers to certify, among other things, that the borrowed "funds !would] be used lo
retain workers and maintain payroll or make mortgage payments, lease payments, and utility
payments."
24. Pursuant lo the CARES Act, the amount of PPP funds a business was eligible to
receive was dcte1111ined by the number of employees the business employed and their average
payroll costs.
25. The PPP allowed qualifying small businesses and other organizations to receive
unsecured SBA-guaranteed loans.
26. The PPP allowed the interest and principa1 to be forgiven if businesses spent the
proceeds on approved expenses under certain conditions.
27. Businesses applying for a PPP loan had lo provide documentation to confirm that
they had in the past paid employees the compensation represented in the loan application.
28. The PPP is overseen and administered by the SBA, which has authority over all
PPP loans, but individual PPP loans were issued by approved commercial lenders who received
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and processed PPP applications and supp01iing documentation. The SBA paid fees to these
commercial lenders to finance PPP loans.
29. The first round of PPP closed to new applications on August 8, 2020. On
December 27, 2020, the Consolidated Appropriations Act of 2021, which included the Economic
Aid to Hard-Hit Small Businesses, Nonprofit, and Venues Act (the "Relief Act") was signed into
law, providing additional funding for the PPP. Under the Relief Act, ce1iain businesses that
already obtained a PPP loan under the original PPP were eligible for an additional "second draw"
PPP loai1, provided they met certain requirements. The Relief Act also re-opened the application
period for "first draw" PPP loans to businesses that had not been approved for a "first draw" loan
prior to August 8, 2020, or who may have been eligible to receive more funds during the "first
draw" period than they actually received. Borrowers through the PPP second draw program are
also eligible to apply for loan forgiveness once all loan proceeds for which forgiveness is
requested have been used.
30. To obtain a PPP loan, an applicant was required to provide business infonnation,
including number of employees, average monthly payroll, and operation date. An applicant was
required to provide suppo1iing documentation, such as payroll documentation, supporting what
payroll taxes were repo1ied to the IRS, typically including IRS Fom1s 940, 941, 1040s, Schedule
C's, W-2s, and W-3s, to conoborate information submitted in the application. The applicant was
required to certify all information in the application was true and correct to the best of the
applicant's knowledge.
31. PPP loan applications were submitted over the Internet by participating
commercial lenders via the SBA's computer servers. PPP loan applications submitted after
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Jamiary 11, 2021, were received by sel'vers in Oregon and transmitted to servers in Virginia via
wire.
32. PPP loan forgiveness applications were submitted over the Internet via the SBA's
computer servers. All PPP loan forgiveness applications were received by servers in Oregon and
transmitted to servers in Virginia via wire.
c. Preferred Lender Program {"PLP")/7{A) Loan Program
33. The ?(a) Loan Program, othe1wise known as the Preferred Lender Program
("PLP") was a loan progran1 offered by the SBA for up to $5 million to fmance the purchase or
statt-up of, or for working capital for, small businesses. PLP Loans were offered to small
businesses or individuals seeking to buy or improve small businesses who might not be eligible
for business loans through normal lending channels.
34. • A PLP lender complying with SBA unde1writing guidelines was eligible for a
SBA guarantee of a substantial part of the loan in the event of a borrower's default. Both the
PLP lender and the SBA must approve the loan for the SBA guarantee to attach.
35. PLP lenders and the SBA relied on the applicants' truthfulness in statements made
on PLP applications and in related documents, or provided through escrow holders or busjness
brokers, and on the genuineness of documents submitted in support of applications, to detennine
whether to approve PLP loans.
36. Mountain America Credit Union in Utah & the West ("MACU',) was a lender
pa1ticipating in the PLP.
Ill
Ill
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COUNTl
(Conspiracy to Defraud the United States)
(18 u.s.c. § 371)
(DAVID STARLING AND BENJAMIN YOUNG)
37. The allegations in paragraphs 1 through 36 of this Indictment are incorporated as
though realleged here.
THE OBJECTS OF THE CONSPIRACY
38. Starting in 2020, and continuing through at least in or about October 2021, in the
District of Oregon and elsewhere, STARLING, YOUNG, Coconspirator 1 (collectively, the
"CONSPIRATORS"), and unnamed coconspirators, known and unknown to the grand jury,
unlawfully, voluntarily, intentionally and knowingly conspired, combined, confederated, and
agreed together and with each other and with other individuals both known and unknown to the
grand jury:
A) To defraud the United States for the purpose of impeding, impairing, obstructing,
and defeating the lawful government functions of the Internal Revenue Service of
the Treasury Department, through deceitful and dishonest means, in the
ascertainment, computation, assessment, and collection of the revenue, that is the
administration and distribution of COVID-Related Tax Ci-edits; and
B) To defraud the Small Business Administration, an agency of the United States,
through deceitful and dishonest means, in its administration of the Payroll
Protection Program and Preferred Lender/7(a) Program.
II I
II I
II I
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MANNER AND MEANS BY WHICH THE CONSPIRACY WAS CARRIED OUT
The Manner and Means by which the conspiracy was sought to be accomplished
included, among others, the following:
Wage Manufacturing Scheme
39. Starting in 2020, the CONSPIRATORS engaged in a scheme to fabricate wages
paid to individuals purported to be employees ("purported employees") of their businesses by
creating paperwork making it appear that the CONSPIRATORS had paid wages to the purpo1ied
employees working for the businesses the CONSPIRATORS owned or controlled, when in fact
these wages had not been paid to the purported employees. The CON SPIRATORS then used
that false infonnation to fraudulently obtain COVID-Related Tax Credits in 2020 and 2021.
40. The CONSPIRATORS shared the names of themselves, their spouses, their
children, including YOUNG's two-year old twins, and others, and listed them as purported
employees for 2020 and 2021 for companies the CONSPIRATORS controlled even though the
CONSPIRATORS knew the purported employees were not actual employees of their companies,
41. The CONSPIRATORS issued checks to the purported employees which the
CONSPIRATORS falsely characterized as ,vages.
42. The CONSPIRATORS filed or caused to be filed Fonns 941 primarily from Q4
2020 through Q3 2021 and requested refundable tax credits for a large part of their fraudulent
payroll. Amounts listed as wages in the Fo1ms 941 were false and did not reflect the amowit of
legitimate wages paid, or amounts paid for the retention of an employee or paid leave, but were
instead fabricated or devised by the CONSPIRATORS based on the maximum amounts of wages
and benefits provided to employees that were subject to the credits. The CONSPIRATORS filed
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or caused to be filed false Forms 941 with the IRS seeking COVID-19 Related Tax Credits for
businesses they owned or controlled as follows:
Total Amount of
Claimed COVID-19
Entity Filing Form 941 QTR Tax Year Date Filed Related Tax Credits
STARLING CPA Q4 2020 02/01/2021 $ 135,824.76
Q1 2021 04/12/2021 $ 98,441.93
Q2 2021 07/23/2021 $ 35,666.30
KAITLYN'S CASES 04 2020 02/01/2021 $ 31,798.19
01 2021 04/12/2021 $ 126,559.38
Q2 2021 07/23/2021 $ 28,579.90
LAKE OSWEGO PROPERTY MANAGEMENT 04 2020 01/13/2021 $ 24,670.00
Q1 2021 04/2612021 $ 54,372.38
02 2021 07/23/2021 $ 94,952.38
03 2021 10/25/2021 $ 20,565.00
GLADYS' MULTISERVICES/TAX PRO Q2 2020 07/18/2020 $ 19,675.37
04 2020 01/06/2021 $ 48,278.24
01 2021 04/29/2021 $ 277,348.29
Q2 2021 07/31/2021 $ 225,735 05
03 2021 10/30/2021 $ 75,244.42
IMMIGRATION SOLUTIONS 04 2020 01/02/2021 $ 52,236.19
01 2021 04/29/2021 $ 27,186.19
02 2021 07/31/2021 $ 71,214.29
03 2021 10/30/2021 $ 13,710.00
STAR PROPERTY HOLDINGS OF UTAH 04 2020 01/13/2021 $ 8,760.00
04 2020 02/03/2021 $ 17,520.00
01 2021 04/29/2021 $ 115,251.76
02 2021 07/31/2021 $ 84,741.57
03 2021 10/30/2021 $ 59,982.89
SQUARE THE BOOKS 02 2020 07/30/2020 $ 20,166.00
03 2020 10/30/2020 $ 2,803.20
04 2020 01/22/2021 $ 15,482.40
04 2020 02/16/2021 $ 130,428.57
01 2021 10/18/2021 $ 190,385.12
Q2 2021 09/27/2021 $ 227,642.86
03 2021 10/11/2021 $ 144,770.87
YOUNG PROPERTIES Q4 2020 02/01/2021 $ 143,324.76
Q1 2021 04/26/2021 $ 106,652.38
Q2 2021 07/24/2021 $ 180,166.67
Q3 2021 10/11/2021 $ 118,644.00
$ 3,028,781.31
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43. The CONSPIRATORS used info1mation from their wage manufacturing scheme
to fraudulently obtain benefits. Relying on the false info1mation provided by the
CONSPIRATORS in 2020 and 2021, the IRS issued Covid-related program benefits (ERC,
SFLC and QFLC) to the companies o,vned or controlled by the CONSPIRATORS in the amount
of $3,028,781.31.
44. In many instances, the CONSPIRATORS used proceeds fi:om their wage
manufacturing tax credit scheme to pay the payroll taxes generated by the scheme.
45. The CONSPIRATORS also used their wage manufacturing scheme, including the
false documents filed with the IRS, to defraud the SBA by submitting or causing to be submitted
fraudulent PPP applications for businesses they owned or controlled on which they
misrepresented the true number of employees and average monthly payroll for the applicant
entities, and misrepresented that the information in the application and the supporting documents
was hue and accurate.
46. Relying on the false information provided by the CONSPIRATORS, the lending
institutions granted the PPP loans, and the SBA approved the guarantees associated with Starling
CPA, Square the Books, and Young Properties.
47. After receiving the PPP loan funds, the CONSPIRATORS then submitted or
caused to be submitted fraudulent PPP forgiveness applications for the loans on which they
misrepresented the number of true employees at the time of the loan applications and time of
forgiveness applications, that all PPP loan proceeds had been spent on payroll, and that the
info1mation in the forgiveness applications was true and correct.
Ill
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Case 3:26-cr-00205-AN Document 1 Filed 06/09/26 Page 13 of 20
48. The PPP applications and PPP forgiveness applications were submitted via
interstate wire through Oregon as follows:
"""""
Date Applica nt Entity Loan orForgiveness Loan }i'ces Forgiven ess
Amount lntercs t
212712021 Square th e nooks Loan #53999285-()0 ____ $42, 887 $2,500
611812021 Square tl1e nooks Forgivc1.1ess #539~99285-00 N/ A $137
3123/2021 Young Propertics Loan #47771586-07_ _ _ $33, 887 $2,500
6118/2021 Yo:i:ing Properties Forgiveness #477 71586-07 N/ A $86.6 0
41612021 yg_ung l)ropert~~~- Loan if7702 I 987-05 $33, 887 $2,500
7/20/2021-------+--~------
Youn Prope11ies Forgiyen~~s #770 21987-05 N/A ···---·-·····
$103.5 4
4/19/2021 ----lr--~-
1e Rooks Loan if58270288-03 $42, 887 -- $2,500
7/28/202] -----f-~
1e Rooks Forgiveness if 582 70288-03 N/A---·-· $125.0 9
4/21/2021 Starling CPA Loan if99236088-09 $36, 850 _$2_,500
6/25/2021 Starling CPA Forgiveness 'if992 36088-09 NIA $64.49
I'u,·chase o{fhe VNPO Propgrtv -with Criminally Derived Monev
49. During the conspiracy, YOUNG, through his company, Square the Rooks,
purchased part of the commercial building where his VNPO employer was located (the "VNPO
Property"). The purchase price was $3.5 million.
50. Part of the funds used by YOUNG to buy the VNPO Propeity were proceeds of
the wage manufacturing scheme provided by STARLING-.
51. To obtain additional funds he needed to buy the VNPO Property, YOUN(r
diverted approximately $2.7 million from VNPO. This amount consisted of approximately
$850,000, which VNPO had received from two PPP loans YOUNG had applied for and obtained
on VNPO 's behalf and an additional approximate $1.85 million YOUNG embezzled from
VNPO.
52. YOUNG closed on the VNPO property on or about June 30, 2021.
Ill
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YOUNG and STARLING Conspired to Fraudulently Obtain a $2.5 ~Million PLP/7a Loan
Through SBA
53, Less than two weeks after YOUNG purchased the VNPO property, he attempted
to repay VNPO the funds he had embezzled from VNPO. To do so, YOUNG applied for an
SBA PLP/7a loan for $2.5 million, through Mountain America Credit Union ("MACU").
54. To help convince MACU to grant the application for the SBA PLP/7a loan,
YOUNG and STARLING created false documents making it appear that STARLING had loaned
YOUNG $2.5 million for the purchase of the VNPO property.
55. Specifically, YOUNG submitted documents to MACU which included a
promissory note stating that STARLING had loaned YOUNG's company, Square the Books,
$2.5 million to buy the VNPO Property.
56. Along with this promissory note, YOUNG provided MACU a payoff statement
signed by STARLING, which affi1111ed that Square the Books owed STARLING $2.5 million.
57. The loan documents, later approved, stated that the PLP/7(a) loan funds would be
sent to STARLING so that the promissory note could be paid by YOUNG for Square the Books.
58. In reality, the promissory note was false and STARLING had not lent $2.5
million to YOUNG or Square the Books.
59. Relying on the false documents and false statements provided by YOUNG and
STARLING, MACU agreed to fund the PLP/7(a) loan.
60. The PLP/7(a) loan proceeds were wired to STARLING. On the same day,
STARLING wired $2.4 million of those funds to VNPO's TD Ameritrade account.
61. Using his authority over VNPO's TD Ameritrade account, YOUNG quickly
transfen-ed the PLP/7(a) loan proceeds to his own TD Ameritrade account.
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62. YOUNG transferred $150,000 of the PLP/7(a) loan proceeds from his TD
Ameritrade account to an account he used Square the Books, and then issued "payroll" checks to
STARLING, STARLING's wife, and to Coconspirator 1, which funds were used as part of the
wage manufacturing scheme.
63. YOUNG transferred an additional $150,000 of the PLP/7(a) loan proceeds from
his TD Ameritrade account to an account he used for another one of his businesses, Young
Properties, and then issued "payroll" checks to STARLING, STARLING's wife, and to
Coconspirator 1, which funds were used as part of the wage manufacturing scheme.
64. YOUNG used approximately $572,000 of the PLP/7(a) loan proceeds to purchase
a condominium occupied by his relatives.
65. YOUNG also used the PLP/7(a) loan proceeds to engage in speculative options
trading. YOUNG transfened approximately $1.37 million of the PLP/7(a) loan proceeds to fund
his options trading. These trades were largely unsuccessful and YOUNG lost virtually all of the
funds.
OVERT ACTS
During and in furtherance of the conspiracy, and to effect the objects thereof, the
following overt acts were committed in the Districts of Oregon, Utah, and elsewhere:
Overt Act 1: On or about December 20, 2020, YOUNG issued two $25,360.08 checks to
STARLING and STARLING'S wife.
Overt Act 2: On or about December 20, 2020, STARLING issued or caused the issuance
of two checks for $9,235 to Coconspirator 1 and Coconspirator 1's wife in Oregon.
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Overt Act 3: On or about March 19, 2021, STARLING issued two $25,036,08 checks to
Coconspirator 1 and Coconspirator 1's wife in Oregon.
Ove1t Act 4: On or about March 18, 2021, Coconspirator 1 issued two checks for
$18,470 to STARLING and STARLING's wife in Oregon.
Overt Act 5: From on or about July 18, 2020, through on or about October 30, 2021,
YOUNG, STARLING, and Coconspirator 1 filed or caused to be filed false Forms 941
with the IRS for their businesses,
Overt Act 6: From on or about February 27, 2021, through on or about July 28, 2021,
YOUNG and STARLING submitted or caused to be submitted fraudulent PPP loan
applications and PPP forgiveness applications.
Overt Act 7: On or about June 25, 2021, YOUNG submitted a promissory note to
MACU purpmtedly signed by YOUNG and STARLING.
Overt Act 8: On or about August 4, 2021, YOUNG submitted a payoff statement to
MACU purportedly signed by STARLING.
Ove1i Act 9: On or about August 5, 2021, STARLING transferred $2,400,000 to
VNPO's TD Ameritrade account ending in 1713.
Overt Act 10: On or about August 10, 2021, YOUNG transfened $2,375,000 from
VNPO's TD Ameritrade account ending in 1713 to his personal TD Ameritrade account
ending in 6098.
Ovett Act 11: From on or about August 11, 2021, through on or about September 15,
2021, YOUNG transfen-ed a total of approximately $1,799,325.34 derived from the
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fraudulent PLP/7(a) loan from YOUNG's personal TD Ameritrade account ending in
6098 into accounts YOUNG controlled.
Overt Act 12: On or about August 11, 2021, YOUNG transfened $300,000 to accounts
YOUNG controlled for his businesses, Young Properties and Square the Books, and then
used these funds to cover "payroll" checks to STARLING, STARLING's wife, and
Coconspirator 1.
Overt Act 13: The CONSPIRATORS engaged in numerous telephone calls during which
they discussed which individuals to add to each of their companies' "payroll" and the
amounts to pay those purported employees,
All in violation of 18 U.S.C. § 371.
COUNTS 2-13
(Wire Fraud)
(18 u.s.c. § 1343)
(BENJAMIN YOUNG)
66. The allegations in paragraphs I through 65 of this Indictment are incorporated as
though realleged herein.
SCHEME TO DEFRAUD
67. Between in or about Febrnmy 2021 and in or about July 2021, BENJAMIN
YOUNG used the wage manufacturing scheme described above, including the false documents
filed with the IRS, to defraud the SBA by submitting or causing to be submitted fraudulent PPP
applications and forgiveness applications for businesses YOUNG owned or controlled in which
YOUNG misrepresented the true number of employees and average monthly payroll for the
applicant entities, and misrepresented that the information in the application and the supporting
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Case 3:26-cr-00205-AN Document 1 Filed 06/09/26 Page 18 of 20
documents was trne and accurate. These applications and forgiveness applications were sent via
interstate wire through Oregon.
68. On or about November 6, 2020, and June 12, 2021, YOUNG submitted fraudulent
PPP forgiveness applications for V1'JPO's PPP loans 54334482-09 and 58988884-08, in which
YOUNG knowingly misrepresented that the entirety of the loans had been spent on VNPO's
payroll and that information in the applications and suppo1ting documents was true and accurate,
causing the lending instihition and the SBA to forgive these PPP loans. These forgiveness
applications were sent via interstate wires through Oregon.
69. On or about the dates set forth below in each count, in the District of Oregon and
elsewhere, YOUNG, for purposes of executing and attempting to execute the material scheme to
defraud, as described above and in Count 1 of this Indictment, and to obtain money and property
by means of materially false and fraudulent pretenses, representations, and promises, knowingly
submitted or caused to be submitted the following communications via ,vire in interstate or
foreign commerce:
Count Approximate Date Interstate Communication
2 11/6/2020 Forgiveness Application for PPP Loan 54334482-09 for
VNPO
3 4/21/2021 Application for PPP Loan 99236088-09 for Starling CPA
4 6/25/2021 Forgiveness Application for PPP Loan 99236088-09 for
Starling CPA
5 2/27/2021 Application for PPP Loan 53999285-00 for Square the Books
6 3/23/2021 Application for PPP Loan 47771586-07 for Young Properties
7 4/6/2021 Annlication for PPP Loan 77021987-05 for Yollll.2: Properties
8 4/19/2021 Aoolication for PPP Loan 58270288-03 for Square the Books
9 6/12/2021 Forgiveness Application for PPP Loan 58988884-08 for
VNPO
10 6/18/2021 Forgiveness Application for PPP Loan 53999285-00 for
Square the Books
11 6/18/2021 Forgiveness Application for PPP Loan 47771586-07 for
Young Properties
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Case 3:26-cr-00205-AN Document 1 Filed 06/09/26 Page 19 of 20
12 7/20/2021 Forgiveness Application for PPP Loan 77021987-05 for
Young Prope1iies
13 7/28/2021 Forgiveness Application for PPP Loan 58270288-03 for
Square the Books
All in violation of 18 U.S.C. § 1343.
FIRST FORFEITURE ALLEGATION
70. Upon conviction of any of the wire fraud offenses alleged in Counts 2-13,
defendant BENJAMIN YOUNG shall forfeit to the United States pursuant to 18 U.S.C. §
981(a)(l)(C) and 28 U.S.C. § 2461(c) any property, real or personal, which constitutes or is
derived from proceeds traceable to the violations, including but not limited to a money judgment
for a sum of money equal to the amount of property involved in or derived from the offenses.
71. If the above-described forfeitable prope1iy, as a result of any act or omission of
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 conuningled with other property which cannot be divided without
difficulty;
the United States of America shall be entitled to forfeiture of substitute prope1iy pursuant to 21
U.S.C. § 853(p), as incorporated by 28 U.S.C. § 2461(c).
II I
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Case 3:26-cr-00205-AN Document 1 Filed 06/09/26 Page 20 of 20
Dated: June q ,2026 A TRUE BILL.
Presented by:
sco
. CARDANI, MA #550609
H D.M. BATEMAN, OSB #192273
Assistant United States Attorneys
Indictment Page 20
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