Information — United States v. Denise Baez, District of Massachusetts (Document 1)
Summary
An information in United States v. Denise Baez, Criminal No. 26cr10131, in the U.S. District Court for the District of Massachusetts, filed April 27, 2026 as Document 1 and signed by Assistant United States Attorney Brian J. Sullivan. Counts One-Two charge wire fraud and aiding and abetting under 18 U.S.C. §§ 1343 and 2, based on wire transfers of $20,833 on April 9, 2021 and April 28, 2021. The information alleges that Baez, a VA Medical Technician, applied to Harvest Small Business Finance, LLC for First Draw and Second Draw PPP loans for a sole proprietorship claimed to have $100,000 in 2019 gross income, supported by false Schedule C forms. It alleges that the SBA forgave both loans after forgiveness applications stated all funds went to payroll, and it seeks a forfeiture money judgment of $41,666.
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“Information — United States v. Denise Baez, District of Massachusetts (Document 1).”
Original at archive.org. Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/information-no-1-26-cr-10131-dkt-1-d-mass-54f3de5a15/
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Case 1:26-cr-10131-PBS Document 1 Filed 04/27/26 Page 1 of 8
UNITED STATES DISTRICT COURT
DISTRICT OF MASSACHUSETTS
) Criminal No. 26cr10131
UNITED STATES OF AMERICA )
) Violations:
v. )
) Counts One-Two: Wire Fraud; Aiding and
DENISE BAEZ, ) Abetting
) (18 U.S.C. §§ 1343 and 2)
Defendant )
) Wire Fraud Forfeiture Allegation:
) (18 U.S.C. § 981(a)(1)(C) and
) 28 U.S.C. § 2461(c))
)
INFORMATION
At all times relevant to this Information:
General Allegations
A. Relevant Individuals and Entities
1. Defendant, DENISE BAEZ (“BAEZ”) was a resident of Brockton, Massachusetts.
2. From August 2021 through the present, BAEZ was a full-time employee of the
United States Department of Veterans Affairs (“VA”) working as a Medical Technician.
3. Harvest Small Business Finance, LLC (“Harvest Finance”) was a non-bank lending
institution headquartered in California. Harvest Finance participated as a lender in a program
referred to as the Paycheck Protection Program (“PPP”) operated by the United States Small
Business Administration (“SBA”). As a PPP lender, Harvest Finance was authorized to lend funds
to eligible borrowers under the terms of the PPP.
4. East West Bank was a federally insured financial institution based in California.
5. Stride Bank, N.A. was a federally insured financial institution based in Oklahoma.
Case 1:26-cr-10131-PBS Document 1 Filed 04/27/26 Page 2 of 8
6. The 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. As part of
this effort, the SBA enabled and provided for loans through banks, credit unions, and other lenders.
These loans have government-backed guarantees.
B. CARES Act Unemployment Benefits
7. The Coronavirus Aid, Relief, and Economic Security (“CARES”) Act was a federal
law enacted in March 2020 and 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 the PPP.
8. 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 (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, the small business (through its authorized representative) was
required to state, among other things, its gross annual income. 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 gross
income.
9. A PPP loan application was processed by a participating lender. If a PPP loan
application was approved, the participating lender funded the PPP loan using its own monies,
2
Case 1:26-cr-10131-PBS Document 1 Filed 04/27/26 Page 3 of 8
which were guaranteed by the Small Business Administration (“SBA”). Data from the application,
including information about 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. This
information was material to the participating lender and the SBA with respect to their respective
decisions to fund and approve PPP loans.
10. PPP loan proceeds were required to be used on certain permissible expenses,
including payroll costs, mortgage interest, rent, and utilities. Under the applicable PPP rules and
guidance, the interest and principal on the PPP loan is 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.
Scheme to Defraud
11. From in or about April 2021 through in or about September 2021, BAEZ devised a
scheme to submit materially false PPP loan applications. In total, BAEZ received $41,666 in PPP
loan funds to which she was not entitled.
A. First Draw PPP Loan
12. On or about April 4, 2021, BAEZ submitted an application to Harvest Finance for
a First Draw PPP loan. The application listed the gross income for a sole proprietorship that
purportedly made $100,000 in gross income in 2019. The application sought a PPP loan in the
amount of $20,833.
13. BAEZ submitted materially false tax documents to support her false assertion that
she had a sole proprietorship with $100,000 in gross income in 2019, including a false Schedule
C tax form.
3
Case 1:26-cr-10131-PBS Document 1 Filed 04/27/26 Page 4 of 8
14. The PPP loan application was approved by Harvest Finance. On or about April 9,
2021, East West Bank, at the instruction of Harvest Finance, distributed $20,833 into BAEZ’s
checking account ending 1631 operated by Stride Bank via an interstate wire.
15. On or about September 3, 2021, BAEZ submitted a loan forgiveness application for
the First Draw PPP loan.
16. In the PPP Loan Forgiveness Application for the First Draw, BAEZ falsely
represented that 100% of the funds from the First Draw PPP Loan were used for payroll. BAEZ used
those funds for other purposes, including personal expenses.
17. Based on the PPP Loan Forgiveness Application for the First Draw, the SBA
forgave the entire PPP loan, plus interest.
B. Second Draw PPP Loan
18. On or about April 10, 2021, BAEZ submitted an application to Harvest Finance for
a Second Draw PPP loan. The application listed the gross income for a sole proprietorship that
purportedly made $100,000 in gross income in 2019. The application sought a PPP loan in the
amount of $20,833.
19. BAEZ submitted materially false tax documents to support her false assertion that
she had a sole proprietorship with $100,000 in gross income in 2019, including a false Schedule
C tax form.
20. The PPP loan application was approved by Harvest Finance. On or about April 28,
2021, East West Bank, at the instruction of Harvest Finance, distributed $20,833 into BAEZ’s
checking account ending 1631 operated by Stride Bank via an interstate wire.
21. On or about September 3, 2021, BAEZ submitted a loan forgiveness application for
the Second Draw PPP loan.
4
Case 1:26-cr-10131-PBS Document 1 Filed 04/27/26 Page 5 of 8
22. In the PPP Loan Forgiveness Application for the Second Draw, BAEZ falsely
represented that 100% of the funds from the Second Draw PPP Loan were used for payroll. BAEZ
used those funds for other purposes, including personal expenses.
23. Based on the PPP Loan Forgiveness Application for the Second Draw, the SBA
forgave the entire PPP loan, plus interest.
5
Case 1:26-cr-10131-PBS Document 1 Filed 04/27/26 Page 6 of 8
COUNTS ONE-TWO
Wire Fraud; Aiding and Abetting
(18 U.S.C. §§ 1343 and 2)
The United States Attorney charges:
24. The United States Attorney re-alleges and incorporates by reference paragraphs 1-
23 of this Information.
25. From in or about April 2021 through in or about September 2021, in the District of
Massachusetts and elsewhere, the defendant,
DENISE BAEZ,
having devised and intending to devise a scheme and artifice to defraud, and for obtaining money
and property by means of materially false and fraudulent pretenses, representations, and promises,
did transmit and cause to be transmitted by means of wire communications in interstate and foreign
commerce, writings, signs, signals, pictures, and sounds for the purpose of executing the scheme
to defraud, as set forth below:
Count Approximate Date Description
1 April 9, 2021 Wire transfer of $20,833 to BAEZ’s checking account
operated by Stride Bank ending 1631 from East West Bank
that was processed via servers in Arizona or Nevada and
received via servers in Oklahoma.
2 April 28, 2021 Wire transfer of $20,833 to BAEZ’s checking account
operated by Stride Bank ending 1631 from East West Bank
that was processed via servers in Arizona or Nevada and
received via servers in Oklahoma.
All in violation of Title 18, United States Code, Sections 1343 and 2.
6
Case 1:26-cr-10131-PBS Document 1 Filed 04/27/26 Page 7 of 8
WIRE FRAUD FORFEITURE ALLEGATION
(18 U.S.C. § 981(a)(1)(C) and 28 U.S.C. § 2461(c))
The United States Attorney further alleges:
26. Upon conviction of one or more of the offenses in violation of Title 18, United
States Code, Section 1343, set forth in Counts One and Two, the defendant,
DENISE BAEZ,
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 asset:
a. $41,666 in U.S. currency, to be entered in the form of a forfeiture money
judgment.
27. If any of the property described in Paragraph 26, 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 26 above.
7
Case 1:26-cr-10131-PBS Document 1 Filed 04/27/26 Page 8 of 8
All pursuant to Title 18, United States Code, Section 981(a)(1)(C), and Title 28, United
States Code, Section 2461(c).
LEAH B. FOLEY
United States Attorney
By: /s/ Brian J. Sullivan
Brian J. Sullivan
Assistant United States Attorney
Date: April 27, 2026
8
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