Information — United States v. Jennai Mance, Southern District of Georgia (Document 1)

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An information filed by the United States Attorney in United States of America v. Jennai Mance, No. 4:22cr-64 (Case 4:22-cr-00064-RSB-CLR), in the U.S. District Court for the Southern District of Georgia, Savannah Division, filed May 12, 2022 as Document 1. Count One charges wire fraud under 18 U.S.C. § 1343 from about March 2021 until about July 2021. It alleges that on or about March 1, 2021 Mance caused a PPP loan application to be submitted to Bank 1 seeking $20,000, falsely stating that Mance was the sole proprietor of a business established on Feb. 15, 2019 with $8,000 in average monthly payroll. It states that Bank 1 deposited approximately $20,000.00 into Mance's account at Bank 2. A forfeiture allegation cites Title 18, United States Code, Section 981(a)(1)(C).

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“Information — United States v. Jennai Mance, Southern District of Georgia (Document 1).” Original at ecf.gasd.uscourts.gov. Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/information-usa-v-mance-dkt-1-deb99d2602/, SHA-256 ea6d27af2a969fe9a8f8d2878a0a2a97c0c462a223e61372eb9231b7d0b974e1.

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Case 4:22-cr-00064-RSB-CLR Document 1 Filed 05/12/22 Page 1 of 6

FILED
John E. Triplett, Clerk of Court
UNITED STATES DISTRICT COURT United States District Court

SOUTHERN DISTRICT OF GEORGIA By jburrell at 4:59 pm, May 12, 2022

SAVANNAH DIVISION

UNITED STATES OF AMERICA ) INFORMATION NO. 4:22cr-64
)
v. ) 18 U.S.C. § 1343
) Wire Fraud
JENNAI MANCE )

THE UNITED STATES ATTORNEY CHARGES THAT:

COUNT ONE
Wire Fraud
18 U.S.C. § 1343

1. In or about March 2021 until in or about July 2021, in Liberty County,

within the Southern District of Georgia, the defendant, JENNAI MANCE, did

knowingly devise and intend to devise a scheme and artifice to defraud, and to obtain

money and property, by means of materially false and fraudulent pretenses,

representations, and promises.

Background

2. The Coronavirus Aid, Relief, and Economic Security (“CARES”) Act was

a federal law enacted in or about March 2020 designed to provide emergency financial

assistance to the millions who are suffering the economic effects caused by the

COVID-19 pandemic.

3. Among other relief efforts, the United States sought to provide financial

support to eligible businesses that could be used to offset certain business expenses.

4. The Small Business Administration (“SBA”) is an executive branch
Case 4:22-cr-00064-RSB-CLR Document 1 Filed 05/12/22 Page 2 of 6

agency of the United States government that provides support to entrepreneurs and

small businesses. The SBA is headquartered in Washington, DC and maintains its

computer servers outside of the State of Georgia. The SBA’s mission is 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.

5. As part of this effort, the SBA enables and provides for loans through

banks, credit unions, and other lenders. These loans have government-backed

guarantees. In addition, the SBA provides loans that come directly from the U.S.

Government.

6. One source of relief provided by the CARES Act was the authorization

of up to $349 billion in forgivable loans to small businesses for job retention and

certain other expenses, through a program referred to as the Paycheck Protection

Program (“PPP”). In or around April 2020, Congress authorized over $300 billion in

additional PPP funding.

7. To obtain a PPP loan, a qualifying business had to submit a PPP loan

application 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 to be

eligible to obtain the PPP loan. In the PPP loan application, the small business

(through its authorized representative) had to state, among other things, its: (a)

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

2
Case 4:22-cr-00064-RSB-CLR Document 1 Filed 05/12/22 Page 3 of 6

then used to calculate the amount of money the small business was eligible to receive

under the PPP. In addition, a business applying for a PPP loan had to provide

documentation showing its payroll expenses.

8. A PPP loan application must be processed by a participating lender,

such as a financial institution. If a PPP loan is approved, the participating lender

funds the PPP loan using its own monies, which are 100% guaranteed by the SBA.

Data from the application, including the information about the borrower, the total

amount of the loan, and the listed number of employees, is transmitted by the lender

to the SBA in the course of processing the loan.

9. The PPP loan proceeds must be used by the business on certain

permissible expenses—payroll costs, interest on mortgages, rent, and utilities. The

PPP allows the interest and principal of the PPP loan to be entirely forgiven if the

business spends the loan proceeds on these expense items within a designated period

of time and uses a certain percentage of the PPP loan proceeds on payroll expenses.

The Scheme

10. Defendant’s scheme was to unjustly enrich herself by obtaining PPP

proceeds under false and misleading pretenses, including by making false statements

in PPP applications.

11. It was part of the scheme and artifice that Defendant, then residing in

the Southern District of Georgia, aided and abetted by others, caused to be submitted

a PPP loan application that contained false statements about a sole proprietorship.

The loan application was submitted via the internet. In particular, on or about March

3
Case 4:22-cr-00064-RSB-CLR Document 1 Filed 05/12/22 Page 4 of 6

1, 2021, Defendant caused to be submitted an electronic PPP loan application to

“Bank 1” seeking $20,000. Such application falsely affirmed, among other

information, that Defendant was the sole proprietor of a business established on Feb.

15, 2019, which had $8,000 in average monthly payroll. Defendant knew these

assertions to be false. Defendant’s PPP applications contained representations that

Defendant well knew were false.

12. In reliance on false representations made in Defendant’s PPP

application, “Bank 1,” headquartered in Delaware, deposited money into Defendant’s

bank account at “Bank 2,” and Defendant thereafter accessed some of these funds in

Georgia.

Execution of the Scheme

13. On or about March 1, 2021, in the Southern District of Georgia, and

elsewhere, JENNAI MANCE, for the purpose of executing the scheme and artifice

described above, and attempting to do so, caused to be transmitted in interstate

commerce, by means of a wire communication, certain signs, signals, and sounds:

that is, Defendant JENNAI MANCE caused to be transmitted an electronic PPP

application from the Southern District of Georgia to Bank 1 in Delaware, which

caused Bank 1 to deposit approximately $20,000.00 into Defendant’s account at Bank

All in violation of Title 18, United States Code, Sections 1343 & 2.

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Case 4:22-cr-00064-RSB-CLR Document 1 Filed 05/12/22 Page 5 of 6

FORFEITURE ALLEGATIONS

The allegations contained in Counts One of this Information are hereby re-

alleged and incorporated by reference for the purpose of alleging forfeiture pursuant

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

Section 2461(c).

Upon conviction of the Title 18 offense set forth in Count One of this

Information, the Defendant JENNAI MANCE, shall forfeit to the United States

pursuant to Title 18, United States Code, Section 981(a)(1)(C), any property, real or

personal, which constitutes or is derived from proceeds traceable to the charged

offense.

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 that cannot be divided without
difficulty,

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).

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Case 4:22-cr-00064-RSB-CLR Document 1 Filed 05/12/22 Page 6 of 6

David H. Estes oward
United States Attorney Assistant United States Attorney
*Lead Counsel

Patricia G. Rhode s
Assistant United States Attorney
Chief, Criminal Division

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