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Information — United States v. Mateus Pina Mendes, Central District of California (Document 1)

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An Information filed August 16, 2022 as Document 1 in United States v. Mateus Pina Mendes, No. 2:22-cr-00371-PA, in the U.S. District Court for the Central District of California, charging wire fraud under 18 U.S.C. § 1343 with criminal forfeiture. It alleges that from around May 2020 through around March 2021 the defendant, claiming to own Multi One Media, CuratedHigh, LLC, Wakeover, Corner the Market and Made in One, submitted PPP and EIDL applications with false employee, payroll and gross receipts figures and false tax documents. According to the Information, the applications sought approximately $184,690.67, the defendant received $143,283.67, and proceeds were used to buy cryptocurrency and gold coins. The charged wire is a transfer of approximately $20,500 in PPP proceeds on or about July 29, 2020.

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“Information — United States v. Mateus Pina Mendes, Central District of California (Document 1).” Original at archive.org. Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/information-no-2-22-cr-00371-dkt-1-c-d-cal-b45820961a/, SHA-256 d00a7e131c740cd2fc0c9abd81468ad10fcd0e87decb9d5442c0eb508111a1e7.

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          Case 2:22-cr-00371-PA Document 1 Filed 08/16/22 Page 1 of 8 Page ID #:1



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                                                                     8/16/2022
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                                                                          jb

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 8                             UNITED STATES DISTRICT COURT

 9                       FOR THE CENTRAL DISTRICT OF CALIFORNIA

10   UNITED STATES OF AMERICA,                  CR No.     2:22-cr-00371-PA
11                Plaintiff,                    I N F O R M A T I O N

12                v.                            [18 U.S.C. § 1343: Wire Fraud; 18
                                                U.S.C. § 981(a)(1)(C), 28 U.S.C.
13   MATEUS PINA MENDES,                        § 2461(c): Criminal Forfeiture]

14                Defendant.

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            The Acting United States Attorney charges:
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                                     [18 U.S.C. § 1343]
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     A.     INTRODUCTORY ALLEGATIONS
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            At times relevant to this Information:
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            Defendant and the Relevant Entities
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            1.    Defendant MATEUS PINA MENDES was a resident of Los Angeles,
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     California.
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            2.    Defendant MENDES claimed to be the owner of Multi One
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     Media, a California company purportedly located in Beverly Hills,
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     California.
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            3.    Defendant MENDES claimed to be the owner of CuratedHigh,
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     LLC, a company registered in Wyoming with a registered business
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     address in Beverly Hills, California.
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       Case 2:22-cr-00371-PA Document 1 Filed 08/16/22 Page 2 of 8 Page ID #:2



 1        4.   Defendant MENDES claimed to be the owner of Wakeover, a

 2   California company purportedly located in Beverly Hills, California.

 3        5.   Defendant MENDES claimed to be the owner of Corner the

 4   Market, a California company purportedly located in Beverly Hills,

 5   California.

 6        6.   Defendant MENDES claimed to be the owner of Made in One, a

 7   California company purportedly located in Los Angeles, California.

 8        7.   Defendant MENDES controlled a personal checking account in

 9   his own name, maintained at Wells Fargo Bank ending in 3113 (the

10   “Wells Fargo 3113 Account”).

11        The Paycheck Protection Program

12        8.   The Coronavirus Aid, Relief, and Economic Security

13   (“CARES”) Act was a federal law enacted in or about March 2020 that

14   was designed to provide emergency financial assistance to Americans

15   suffering economic harm as a result of the COVID-19 pandemic.               One

16   form of assistance provided by the CARES Act was the authorization of

17   United States taxpayer funds in forgivable loans to small businesses

18   for job retention and certain other expenses, through a program

19   referred to as the Paycheck Protection Program (“PPP”).

20        9.   In order to obtain a PPP loan, a qualifying business was

21   required to submit a PPP loan application signed by an authorized

22   representative of the business.       The PPP loan application required

23   the small business (through its authorized representative) to

24   acknowledge the program rules and make certain affirmative

25   certifications in order to be eligible to obtain the PPP loan.              One

26   such certification required the applicant to affirm that “[t]he [PPP

27   loan] funds w[ould] be used to retain workers and maintain payroll or

28   make mortgage interest payments, lease payments, and utility

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       Case 2:22-cr-00371-PA Document 1 Filed 08/16/22 Page 3 of 8 Page ID #:3



 1   payments.”    The applicant (through its authorized representative) was

 2   also required to acknowledge that “I understand that if the funds are

 3   used for unauthorized purposes, the federal government may pursue

 4   criminal fraud charges.”     In the PPP loan application, the applicant

 5   was required to state, among other things, its: (a) average monthly

 6   payroll expenses; and (b) number of employees.         These figures were

 7   used to calculate the amount of money the small business was eligible

 8   to receive under the PPP.     In addition, the applicant was required to

 9   provide documentation showing its payroll expenses.

10        10.     A business’s PPP loan application was received and

11   processed, in the first instance, by a participating financial

12   institution.    If a PPP loan application was approved, the

13   participating financial institution would fund the PPP loan using its

14   own monies.

15        11.     PPP loan proceeds were required to be used by the business

16   on certain permissible expenses, namely, payroll costs, interest on

17   mortgages, rent, and utilities.       The PPP allowed the interest and

18   principal on the PPP loan to be entirely forgiven if the business

19   spent the loan proceeds on these expenses within a designated period

20   of time and used at least a minimum amount of the PPP loan proceeds

21   towards payroll expenses.

22        The Economic Injury Disaster Loan Program

23        12.     The Economic Injury Disaster Loan Program (“EIDL”) was a

24   United States Small Business Administration (“SBA”) program that

25   provided low-interest financing to small businesses, renters, and

26   homeowners in regions affected by declared disasters.

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       Case 2:22-cr-00371-PA Document 1 Filed 08/16/22 Page 4 of 8 Page ID #:4



 1        13.     The CARES Act authorized the SBA to provide EIDL loans of

 2   up to $2 million to eligible small businesses experiencing

 3   substantial financial disruption due to the COVID-19 pandemic.

 4        14.     To obtain an EIDL loan, a qualifying business was required

 5   to submit an application to the SBA and provide information about the

 6   business’s operations, such as the number of employees, gross

 7   revenues for the 12-month period preceding the disaster, and cost of

 8   goods sold in the 12-month period preceding the disaster.           In the

 9   case of EIDL loans for COVID-19 relief, the 12-month period was the

10   12-month period from January 31, 2019, to January 31, 2020.            The

11   applicant was also required to certify that all of the information in

12   the application was true and correct to the best of the applicant’s

13   knowledge.

14        15.     EIDL loan applications were submitted directly to the SBA

15   and processed by the agency with support from a government

16   contractor.    The amount of the loan, if the application was approved,

17   was determined based, in part, on the information provided by the

18   applicant about employment, revenue, and cost of goods sold.            Any

19   funds issued under an EIDL loan were issued directly by the SBA.

20        16.     EIDL loan funds could be used for payroll expenses, sick

21   leave, production costs, and business obligations, such as debts,

22   rent, and mortgage payments.      If the applicant also obtained a loan

23   under the PPP, the EIDL loan funds could not be used for the same

24   purpose as the PPP loan funds.

25        SBA-Approved PPP Service Providers and Lenders

26        17.     Company 1 was a technology company located in New York

27   City, New York and headquartered in Delaware that engaged in lending

28   to small businesses.     Company 1 participated in the SBA’s PPP as an

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          Case 2:22-cr-00371-PA Document 1 Filed 08/16/22 Page 5 of 8 Page ID #:5



 1   SBA-approved PPP lender.        Small businesses seeking PPP loans could

 2   apply to Company 1 for PPP loans.          Company 1 would review the loan

 3   applications and, if the application was approved for funding,

 4   Company 1 would disburse the loan funds to the applicant.

 5   B.     SCHEME TO DEFRAUD

 6          18.   Beginning in or around May 2020 and continuing through in

 7   or around March 2021, in Los Angeles County, within the Central

 8   District of California, and elsewhere, defendant MENDES, knowingly

 9   and with intent to defraud, devised, participated in, and executed a

10   scheme to defraud the SBA and SBA-approved lenders as to material

11   matters, and to obtain money from the SBA and such lenders by means

12   of materially false and fraudulent pretenses, representations, and

13   promises.

14          19.   The fraudulent scheme operated and was carried out, in

15   substance, as follows:

16                a.    Defendant MENDES made and caused to be made, false

17   statements to the SBA, financial institutions, and other lenders in

18   connection with the fraudulent applications for PPP and EIDL loans,

19   including false representations regarding the number of employees to

20   whom the companies had paid wages, the average monthly payroll, the

21   gross receipts earned by the purported businesses, and false

22   certifications that the loans would be used for permissible business

23   purposes.

24                b.    Defendant MENDES electronically submitted, and caused

25   to be submitted, false and fictitious documents to the SBA and

26   financial institutions in support of the fraudulent PPP and EIDL loan

27   applications, including false tax documents.

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 1                c.    In each of the PPP and EIDL applications submitted by

 2   defendant MENDES, he certified that, as the authorized representative

 3   of the businesses on whose behalf the applications were submitted, he

 4   knew and understood the terms and rules of the PPP and EIDL programs,

 5   and that the funds were to be used by the recipient to only pay

 6   certain authorized business expenses.

 7                d.    Defendant MENDES knowingly misappropriated and misused

 8   the PPP and EIDL loan proceeds for his own personal benefit,

 9   including for expenses prohibited under the requirements of the PPP

10   and EIDL programs, such as the purchase of cryptocurrency and gold

11   coins for personal use and investment.

12                e.    From in or around May 2020 and continuing through in

13   or around March 2021, in furtherance of his scheme, defendant MENDES

14   submitted and caused to be submitted fraudulent PPP and EIDL loan

15   applications seeking approximately $184,690.67, and actually received

16   $143,283.67 in PPP and EIDL proceeds to which he was not entitled.

17   C.     USE OF AN INTERSTATE WIRE

18          20.   On or about July 29, 2020, in Los Angeles County, within

19   the Central District of California, and elsewhere, for the purpose of

20   executing the above-described scheme to defraud, namely, the

21   misappropriation and misuse of the PPP loan proceeds fraudulently

22   obtained for Multi One Media, defendant MENDES caused others to

23   transmit, by means of wire communications in interstate commerce,

24   approximately $20,500 in PPP loan proceeds from Company 1 into the

25   Wells Fargo 3113 Account.

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          Case 2:22-cr-00371-PA Document 1 Filed 08/16/22 Page 7 of 8 Page ID #:7



 1                                 FORFEITURE ALLEGATION

 2                [18 U.S.C. § 981(a)(1)(C) and 28 U.S.C. § 2461(c)]

 3          1.    Pursuant to Rule 32.2 of the Federal Rules of Criminal

 4   Procedure, notice is hereby given that the United States of America

 5   will seek forfeiture as part of any sentence, pursuant to Title 18,

 6   United States Code, Section 981(a)(1)(C), and Title 28, United States

 7   Code, Section 2461(c), in the event of the defendant MATEUS PINA

 8   MENDES’s conviction of the offense set forth in the sole count of

 9   this Information.

10          2.    Defendant MENDES, if so convicted, shall forfeit to the

11   United States of America the following:

12                a.    All right, title, and interest in any and all

13   property, real or personal, constituting, or derived from, any

14   proceeds traceable to the offense; and

15                b.    To the extent such property is not available for

16   forfeiture, a sum of money equal to the total value of the property

17   described in subparagraph (a).

18          3.    Pursuant to Title 21, United States Code, Section 853(p),

19   as incorporated by Title 28, United States Code, Section 2461(c),

20   defendant MENDES, if so convicted, shall forfeit substitute property,

21   up to the value of the property described in the preceding paragraph

22   if, as the result of any act or omission of defendant MENDES, the

23   property described in the preceding paragraph or any portion thereof

24   (a) cannot be located upon the exercise of due diligence; (b) has

25   been transferred, sold to, or deposited with a third party; (c) has

26   been placed beyond the jurisdiction of the court; (d) has been

27   //

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       Case 2:22-cr-00371-PA Document 1 Filed 08/16/22 Page 8 of 8 Page ID #:8



 1   substantially diminished in value; or (e) has been commingled with

 2   other property that cannot be divided without difficulty.

 3                                          STEPHANIE S. CHRISTENSEN
                                            Acting United States Attorney
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 6                                          SCOTT M. GARRINGER
                                            Assistant United States Attorney
 7                                          Chief, Criminal Division
 8                                          RANEE A. KATZENSTEIN
                                            Assistant United States Attorney
 9                                          Chief, Major Frauds Section
10                                          LORINDA I. LARYEA
                                            Acting Chief, Fraud Section
11                                          Criminal Division
                                            United States Department of
12                                          Justice
13                                          SCOTT PAETTY
                                            Assistant United States Attorney
14                                          Deputy Chief, Major Frauds Section
15                                          JENNIFER BILINKAS
                                            Trial Attorney, Fraud Section
16                                          Criminal Division
                                            United States Department of
17                                          Justice
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