Information — United States v. Hope Leticia Hastey, Northern District of Texas (Document 3)

Summary

A criminal information against Hope Leticia Hastey, No. 5:23-cr-00077, filed August 2, 2023 as Document 3 in the U.S. District Court for the Northern District of Texas, Lubbock Division. Count One charges misprision of a felony under 18 U.S.C. § 4, alleging that Hastey knew of bank fraud committed by another to obtain Paycheck Protection Program loans and concealed it, up to on or about May 18, 2020, by writing and depositing a check to make it appear the loan proceeds were used for authorized purposes. The forfeiture notice seeks a money judgment of no less than $3,387,347.50, funds seized from bank accounts in 2022, vehicles including Peterbilt tractors and a Caterpillar excavator, and real property in Lubbock. It is filed by United States Attorney Leigha Simonton and Assistant United States Attorney Ann Howey.

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Case 5:23-cr-00077-H-BV Document3 Filed 08/02/23. Pagelof4 PagelD3

IN THE UNITED STATES DISTRICT COURT (05°80 -2 PH ':S9
FOR THE NORTHERN DISTRICT OF TEXAS y
LUBBOCK DIVISION EU NL
UNITED STATES OF AMERICA
V. Case No.

HOPE LETICIA HASTEY

INFORMATION
The United States Attorney Charges:
Count One
Misprision of a Felony
(Violation of 18 U.S.C. § 4)

From on or about a date unknown to on or about May 18, 2020, in the Lubbock
Division of the Northern District of Texas, and elsewhere, Hope Leticia Hastey, having
knowledge of the commission of a felony, that is, Bank Fraud, a violation of Title 18,
United States Code, Section 1344(2), that was committed by another to obtain Paycheck
Protection Program loans, did conceal the same by writing and depositing a check to
make it appear as though proceeds from the fraudulently obtained loans were used for
purposes authorized under the loan program and did not as soon as possible make known
the felony a federal judge or other person in civil and military authority under the United

States.

In violation of Title 18, United States Code, Section 4.

Hope Leticia Hastey
Information — Page 1
Case 5:23-cr-00077-H-BV Document3 _ Filed 08/02/23. Page2of4 PagelD4

Forfeiture Notice
[18 U.S.C. § 981(a)(1)(C), 28 U.S.C. § 2461(c)]

Upon conviction for the offense set forth in Count One of this information, the
defendant, Hope Leticia Hastey, shall forfeit to the United States of America, pursuant
to 18 U.S.C. § 981(a)(1)(C) and 28 U.S.C. § 2461(c), any property, real or personal,
constituting, or derived from, proceeds obtained directly or indirectly, as the result of the
offense.

The property to be forfeited includes, but is not limited to, the following:

a, All proceeds obtained as a result of the offense in Count One, in the form of
‘a money judgment in an amount of no less than $3,387,347.50 (to be reduced by the post-
forfeiture recognized value of the assets below);

b. $58,488.10 in funds seized on or about July 20, 2022, from an Amarillo
National Bank account with a number ending in 3741;

c. $1,182.33 in funds received or about July 20, 2022, from Happy State Bank
concerning a seizure warrant served on Happy State Bank for the account with an account
number ending in 7921;

d. $1,272.12 in funds received on or about July 20, 2022, from Happy State
Bank concerning a seizure warrant served on Happy State Bank for the account with an
account number ending in 7846;

e. $38,754.74 in funds seized on or about August 2, 2022, from a First United
Bank account with an account number ending in 6485;

f. $48,580.95 in funds seized on or about August 17, 2022, from a First
United Bank account with an account number ending in 6515;

g. $19,016.11 in funds seized on or about September 2, 2022, from an
Amarillo National Bank account with an account number ending in 2508;

h. $10,702.48 in funds seized on or about September 2, 2022, from a First
United Bank account with an account number ending in 2928;

Hope Leticia Hastey
Information — Page 2
Case 5:23-cr-00077-H-BV Document3 _ Filed 08/02/23. Page3of4 PagelD5

i. $6,119.43 in funds seized on or about September 2, 2022, from an Amarillo
National Bank account with an account number ending in 7054;

j. $26,815.11 in funds seized on or about September 2, 2022, from a First
United Bank account with an account number ending in 2944;

k. the 2020 Peterbilt 389 tractor, VIN INPXX4EXXLD683659, license plate
R576359;

1. the 2018 Peterbilt 389 tractor, VIN INPXGGGG80D273341, license plate
R576358;

m. the 2022 Caterpillar Excavator 308, VIN 0GG804960;

n. the 2021 Jeep Gladiator Mojave, VIN 1C6JJTEG7ML543589, license plate
PVH8426;

0. the 2021 Lincoln Corsair, VIN SLMCJ1C91MUL23703, license plate
RHW8591;

p. the 2022 Kia K5 GT, VIN 5XXG44J81NG097701, license plate PZR2476;

q. the 2021 Jeep Wrangler Unlimited Rubicon, VIN 1C4HIXFG5MW758173,
license plate PZR2387; .

r, the 2021 Load Trail trailer, VIN 4ZEGH3225M1236193, license plate
580022K;

Ss. the 2021 Lincoln Navigator Reserve, VIN 5LMJJ2LT7MEL17164, license
plate PZR2846;

t. the 2020 Ford Explorer ST, VIN 1FM5K8GC5LGC98468, license plate
NNN2674; and

u. the real property (the lot or parcel of land, together with all buildings,
improvements, fixtures, attachments, and easements) located at 11110 Detroit Avenue,
Lubbock, Lubbock County, Texas, more specifically described as Lot One Hundred
Thirty (130), Cooper Creek Addition to the City of Lubbock, Lubbock, County, Texas,
according to the Map, Plat, and/or Dedication Deed thereof, recorded in Volume 10061,
Page 174, Official Public Records of Lubbock County, Texas.

Hope Leticia Hastey
Information — Page 3
Case 5:23-cr-00077-H-BV Document3 Filed 08/02/23. Page4of4 PagelD6

If, as set forth under 21 U.S.C. § 853(p), any property described above cannot be
located upon the exercise of due diligence; has been transferred or sold to, or deposited
with, a third party; has been placed beyond the jurisdiction of the court; has been
substantially diminished in value; or has been commingled with other property which
cannot be divided without difficulty, all other property of the defendant, to the extent of

the value of the property directly subject to forfeiture, shall be subject to forfeiture, as

substitute property.

LEIGHA SIMONTON

UNITED STATES ATTORNEY
ANN HOWEY O

Assistant United States Attorney
Texas State Bar No. 24032312

1205 Texas Avenue, Suite 700
Lubbock, Texas 79401

Telephone: (806) 472-7351
Facsimile: (806) 472-7394
E-mail: ann.howey@usdoj.gov

Hope Leticia Hastey
Information — Page 4


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