Information — United States v. Kurtis James Vandermolen, Western District of Michigan (ECF No. 1)

Summary

A felony information against Kurtis James Vandermolen in the United States District Court for the Western District of Michigan, Southern Division, Case 1:22-cr-00171-RJJ, filed December 8, 2022 as ECF No. 1. Count 1 charges bank fraud under 18 U.S.C. § 1344(2), alleging that on or about July 23, 2020 Vandermolen submitted a Paycheck Protection Program loan application to Cross River Bank for a fictitious company, Breakout Strategies Corporation, resulting in the deposit of $100,641. Count 2 charges money laundering under 18 U.S.C. § 1957 over an $18,752 withdrawal on or about September 1, 2020 used to complete the purchase of a 2010 BMW 650i convertible. The forfeiture allegation lists CZ firearms and a money judgment of at least $170,002.

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Case 1:22-cr-00171-RJJ ECF No.1, PagelD.1 Filed 12/08/22 Page 1 of 4

UNITED STATES DISTRICT COURT
WESTERN DISTRICT OF MICHIGAN
SOUTHERN DIVISION
UNITED STATES OF AMERICA,
Plaintiff,

VS.

KURTIS JAMES VANDERMOLEN,

FILED - GR

December 8, 2022 1:10 PM
CLERK OF COURT
U.S. DISTRICT COURT
WESTERN DISTRICT OF MICHIGAN

BY:JMW SCANNED BY: i %

1:22-cr-171
Robert J. Jonker
U.S. District Judge

FELONY INFORMATION

Defendant.
/

The United States Attorney charges:

COUNT 1
(Bank Fraud)

On or about July 23, 2020, in Kent County, in the Southern Division of the Western District

of Michigan, and elsewhere, the defendant,

KURTIS JAMES VANDERMOLEN,

knowingly, and with the intent to defraud, executed a scheme and artifice to obtain, by means of

false and fraudulent pretenses, representations, and promises, moneys and funds owned by, and

under the control of, Cross River Bank, a financial institution, by submitting a Paycheck Protection

Program loan application for a fictitious company, Breakout Strategies Corporation, that resulted

in the deposit of $100,641 in loan proceeds in a credit union account in the Western District of

Michigan.

18 U.S.C. § 1344(2)
Case 1:22-cr-00171-RJJ ECF No.1, PagelD.2 Filed 12/08/22 Page 2 of 4

COUNT 2
(Money Laundering)

On or about September 1, 2020, in Kent County, in the Southern Division of the Western

District of Michigan, and elsewhere, the defendant,
KURTIS JAMES VANDERMOLEN,

knowingly engaged in a monetary transaction, in and affecting commerce, in criminally derived
property of a value greater than $10,000 that was derived from a specified unlawful activity.
Specifically, while engaged in the scheme and artifice to defraud described in Count 1 of this
Felony Information and incorporated herein by reference, the defendant withdrew $18,752 from
the Breakout Strategies Corporation account at Consumers Credit Union on check number 1105
and thereby made payment to complete the purchase of a 2010 BMW 650i convertible.

18 U.S.C. § 1957
Case 1:22-cr-00171-RJJ ECF No.1, PagelD.3 Filed 12/08/22 Page 3 of 4

FORFEITURE ALLEGATION
(Bank Fraud)

The allegations contained in Count 1 of this Information are re-alleged and incorporated
by reference as if set forth fully herein for the purpose of alleging forfeiture pursuant to 18 U.S.C.
§ 982(a)(2)(A) and 28 U.S.C. § 2461(c).

Pursuant to 18 U.S.C. § 982(a)(2)(A), upon conviction of bank fraud in violation of 18
U.S.C. § 1344(2) as set forth in Count | of this Information, the defendant,

KURTIS JAMES VANDERMOLEN,
shall forfeit to the United States of America any property constituting, or derived from, proceeds
obtained, directly or indirectly, as a result of such violation. The property to be forfeited includes,
but is not limited to, the following:

i PERSONAL PROPERTY: CZ firearms with serial numbers UC11369 and
UC12145.

2. MONEY JUDGMENT. A sum of money equal to at least $170,002, which
represents the amount of gross proceeds obtained, directly or indirectly, from the offense charged
in Count 1.

i SUBSTITUTE ASSETS. 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,
Case 1:22-cr-00171-RJJ ECF No.1, PagelD.4 Filed 12/08/22 Page 4of4

the United States of America shall be entitled to forfeiture of substitute property pursuant to 21
U.S.C. § 853(p), as incorporated by 28 U.S.C. § 2461(c).

18 U.S.C. § 982(a)(2)(A)
21 U.S.C. § 853(p)
18 U.S.C. § 1344(2)

MARK A. TOTTEN
United States Attorney

Date: December 8, 2022 bedoad x. Or a

ADAM B. TOWNSHEND
Assistant United States Attorney


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