Information — United States v. Jesse Lelievre, District of Massachusetts (Document 1)

Summary

A criminal information against Jesse Lelievre, Case 1:24-cr-10217-DJC, in the U.S. District Court for the District of Massachusetts, filed July 29, 2024 as Document 1. Count One charges theft of government property under 18 U.S.C. § 641, alleging that Lelievre, owner of Paramount Plumbing & Heating LLC, misappropriated EIDL funds having a value of more than $150,000 between about January 2022 and September 2022. It states Lelievre received approximately $1,222,000 from the SBA on or about January 6, 2022 and then used loan funds for landscaping and remodeling at his home and approximately $83,000 for a diamond ring. The information seeks a forfeiture money judgment to be determined at sentencing and is signed by Assistant United States Attorney Christopher J. Markham.

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“Information — United States v. Jesse Lelievre, District of Massachusetts (Document 1).” Original at archive.org. Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/information-no-1-24-cr-10217-dkt-1-d-mass-ff1b4f103b/, SHA-256 d14b92dbb3395df51907d0768d52611329f72b8eff539fd827dae2d71def3ab7.

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Case 1:24-cr-10217-DJC Document 1 Filed 07/29/24 Page 1 of 6

UNITED STATES DISTRICT COURT
DISTRICT OF MASSACHUSETTS

) Criminal No. 24cr10217
UNITED STATES OF AMERICA )
) Violation:
v. )
) Count One: Theft of Government Property
JESSE LELIEVRE, ) (18 U.S.C. § 641)
)
Defendant ) Forfeiture Allegation:
) (18 U.S.C. § 981(a)(1)(C) and
) 28 U.S.C. § 2461)
)

INFORMATION

At all times relevant to this Information:

General Allegations

1. The defendant, JESSE LELIEVRE (“LELIEVRE”), resided in North Andover,

Massachusetts.

2. LELIEVRE was the owner and manager of Paramount Plumbing & Heating LLC

(“Paramount Plumbing & Heating”), a Massachusetts company that provided plumbing, heating,

and related services.

3. The Economic Injury Disaster Loan (“EIDL”) program provided loans to small

businesses that suffered substantial economic injury due to a declared disaster. This program was

expanded to provide relief to businesses that experienced a loss in revenue during the COVID-19

pandemic. The U.S Small Business Administration (“SBA”) administered the EIDL program.
Case 1:24-cr-10217-DJC Document 1 Filed 07/29/24 Page 2 of 6

Theft of Government Property

4. Between in or about January 2022 and in or about September 2022, LELIEVRE

applied for and obtaining a loan from SBA through the EIDL program to support his business,

Paramount Plumbing & Heating. LELIEVRE thereafter misappropriated a portion of the EIDL

funds for personal purposes, including to buy a diamond ring and to remodel his home.

5. In or about 2021, LELIEVRE submitted an application to the SBA for a loan

through the EIDL program.

6. On or about December 22, 2021, LELIEVRE entered into a loan agreement with

the SBA to participate in the EIDL program. As part of the agreement, LELIEVRE agreed, among

other things, to “use all the proceeds of this Loan solely as working capital to alleviate economic

injury” caused by the COVID-19 pandemic.

7. On or about January 6, 2022, LELIEVRE received approximately $1,222,000 from

SBA into an account at Bank of America that he controlled (“LELIEVRE’s BoA Account”).

8. On or about February 16, 2022, LELIEVRE used approximately $13,000 from

LELIEVRE’s BoA Account to pay for landscaping services at his home.

9. On or about April 13, 2022, LELIEVRE used approximately $4,800 from

LELIEVRE’s BoA Account to pay for heating, ventilation, and air conditioning services at his

home.

10. On or about May 24, 2022, LELIEVRE used approximately $83,000 from

LELIEVRE’s BoA Account to pay for a diamond ring that he purchased as a gift for his spouse.

11. On or about August 5, 2022, LELIEVRE used approximately $7,000 from

LELIEVRE’s BoA Account to pay for additional landscaping services at his home.

2
Case 1:24-cr-10217-DJC Document 1 Filed 07/29/24 Page 3 of 6

12. On or about September 14, 2022, LELIEVRE used approximately $30,000 from

LELIEVRE’s BoA Account to pay for remodeling services at his home.

13. On or about September 20, 2022, LELIEVRE used approximately $41,290 from

LELIEVRE’s BoA Account to pay for additional remodeling services at his home.

3
Case 1:24-cr-10217-DJC Document 1 Filed 07/29/24 Page 4 of 6

COUNT ONE
Theft of Government Property
(18 U.S.C. § 641)

The U.S. Attorney charges:

14. The U.S. Attorney re-alleges and incorporates by reference paragraphs 1 through

13 of this Information.

15. From in or about January 2022 through in or about September 2022, in the District

of Massachusetts and elsewhere, the defendant,

JESSE LELIEVRE,

did knowingly and willfully embezzle, steal, purloin, and convert to his use and the use of another

any money and thing of value of the United States and of any department and agency thereof, in a

total amount greater than $1,000, namely EIDL funds having a value of more than $150,000.

All in violation of Title 18, United States Code, Section 641.

4
Case 1:24-cr-10217-DJC Document 1 Filed 07/29/24 Page 5 of 6

FORFEITURE ALLEGATION
(18 U.S.C. § 981(a)(1)(C) and 28 U.S.C. § 2461(c))

The Grand Jury further finds:

16. Upon conviction of the offense in violation of Title 18, United States Code, Section

641, set forth in Count One, the defendant,

JESSE LELIEVRE,

shall forfeit to the United States, pursuant to Title 18, United States Code, Section 981(a)(1)(C),

and Title 28, United States Code, Section 2461(c), any property, real or personal, which

constitutes or is derived from proceeds traceable to the offenses. The property to be forfeited

includes, but is not limited to, the following assets:

a. A forfeiture money judgment to be determined at sentencing.

17. If any of the property described in Paragraph 16, above, as being forfeitable

pursuant to Title 18, United States Code, Section 981(a)(1)(C), and Title 28, United States Code,

Section 2461(c), 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;

it is the intention of the United States, pursuant to Title 28, United States Code, Section 2461(c),

incorporating Title 21, United States Code, Section 853(p), to seek forfeiture of any other property

of the defendant up to the value of the property described in Paragraph 16 above.
5
Case 1:24-cr-10217-DJC Document 1 Filed 07/29/24 Page 6 of 6

All pursuant to Title 18, United States Code, Section 981(a)(1)(C), and Title 28, United

States Code, Section 2461(c).

JOSHUA S. LEVY
ACTING UNITED STATES ATTORNEY

By: /s/ Christopher J. Markham
CHRISTOPHER J. MARKHAM
ASSISTANT UNITED STATES ATTORNEY

DATE: July 29, 2024

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