Information — United States v. Matthew Patsches, Southern District of Georgia (Document 1)

Summary

An information filed by the United States Attorney in United States of America v. Matthew Patsches, No. 4:22cr-67 (Case 4:22-cr-00067-RSB-CLR), in the U.S. District Court for the Southern District of Georgia, Savannah Division, filed May 17, 2022 as Document 1. Count One charges conspiracy to commit wire fraud under 18 U.S.C. § 1349 from about April 2021 through about June 2021 with a coconspirator identified as CC-1. It alleges that a PPP application submitted to Fountainhead SBF LLC in Patsches's name falsely claimed a business called "Matt's personal training" with $59,670 in gross income for 2020, supported by a false Schedule C, followed by a second draw application through Capital Plus. It states that each lender deposited $12,431, on or around May 4, 2021 and June 28, 2021, and that Patsches paid CC-1 $3,500 as a kickback.

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“Information — United States v. Matthew Patsches, Southern District of Georgia (Document 1).” Original at ecf.gasd.uscourts.gov. Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/information-usa-v-patsches-dkt-1-7fc90aa577/, SHA-256 2986d459148c5ac037e5e167324a2212291130d0b3c910657f8ab539744f809e.

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Case 4:22-cr-00067-RSB-CLR Document 1 Filed 05/17/22 Page 1 of 4
FILED
John E. Triplett, Clerk of Court
United States District Court

By jburrell at 1:05 pm, May 17, 2022

UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF GEORGIA
SAVANNAH DIVISION

UNITED STATES OF AMERICA ) INFORMATION NO. 4:22cr-67
)
v. ) 18 U.S.C. § 1349
) Conspiracy to Commit Wire Fraud
MATTHEW PATSCHES )

THE UNITED STATES ATTORNEY CHARGES THAT:

COUNT ONE
Conspiracy to Commit Wire Fraud
18 U.S.C. § 1349

1. Beginning in or around April 2021 and continuing through in or around

June 2021, within the Southern District of Georgia, Western District of Texas, and

elsewhere, the defendant,

MATTHEW PATSCHES,

did knowingly and willfully combine, conspire, confederate, and agree with

Coconspirator 1 (“CC-1”) to devise or intend to devise a scheme or artifice to defraud,

and for obtaining money or property by means of false or fraudulent pretenses,

representations, or promises, and to transmit or cause to be transmitted by wire

communication in interstate commerce any writings, signs, signals, pictures, or

sounds for the purpose of executing such scheme or artifice, in violation of 18 U.S.C.

§ 1343, the conspiracy to commit such offense being in violation of 18 U.S.C. § 1349.

2. The object of the conspiracy was for Defendant and CC-1 to unjustly

enrich themselves by making false statements in loan applications electronically

submitted to financial institutions through the Payroll Protection Program (PPP) to
Case 4:22-cr-00067-RSB-CLR Document 1 Filed 05/17/22 Page 2 of 4

unlawfully induce the financial institutions to dispense money and funds to

Defendant to which he was not entitled, and Defendant, in turn, would pay a portion

of the ill-gotten funds to CC-1 as a kickback.

3. In furtherance of this scheme, and to effect the objects thereof, the

following acts were committed in furtherance of the conspiracy:

a. It was part of the conspiracy that in or about April 2021,

Defendant and CC-1 utilized cellular devices, email, and the internet to create a

fraudulent PPP application.

b. Defendant sent his personal identifying information to CC-1, who

in turn, used the internet to create a fraudulent PPP bank loan application.

c. In particular, the conspirators caused to be submitted through

interstate wire a PPP bank loan application with Fountainhead SBF LLC in

Defendant’s name that falsely represented Defendant had a business called “Matt’s

personal training” established on January 1, 2019, and that such business had

$59,670 in gross income for tax year 2020, when in truth and fact, as Defendant and

CC-1 both knew, Defendant had no such business.

d. In support of the fraudulent application, CC-1 caused to be

submitted a false and fraudulent IRS Form Schedule C.

e. Thereafter, in or around June 2021, CC-1 caused to be submitted

a second draw PPP application through Capital Plus financial institution that made

false claims similar to those in the first draw application.

2
Case 4:22-cr-00067-RSB-CLR Document 1 Filed 05/17/22 Page 3 of 4

4. In reliance on false representations made in the PPP applications,

Fountainhead SBF LLC, by means of wire communication, deposited $12,431 into

Defendant’s bank account on or around May 4, 2021, and Capital Plus deposited

$12,431 into Defendant’s bank account on or around June 28, 2021.

5. In exchange for CC-1 completing fraudulent PPP loan applications,

Defendant agreed to pay and did pay CC-1 $3,500, which was transmitted by wire.

All in violation of Title 18, United States Code, Section 1349.

3
Case 4:22-cr-00067-RSB-CLR Document 1 Filed 05/17/22 Page 4 of 4

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

~9C~
Patricia G. Rhodes
Assistant United States Attorney
Chief, Criminal Division

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