United States v. John David Scoggins — Plea Agreement, Northern District of Alabama (Document 22)

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A Plea Agreement between the Government and defendant John David Scoggins in United States v. Jennifer Corrine Scoggins and John David Scoggins, Case No. 5-23-CR-00087-MHH-HNJ, in the U.S. District Court for the Northern District of Alabama, filed 09/13/23 as Document 22. The defendant agrees to plead guilty to Count One, conspiracy to commit wire fraud under Title 18, United States Code, Section 1349, and the Government agrees to dismiss Counts Two through Five as to him. The factual basis states the Scoggins applied for and received approximately $1.14 million in fraudulent PPP loans in 2021 for Scoggins Construction I LLC, Sawdust Construction, Blue Ladder Construction and River Peach Apparel. The parties stipulate a loss greater than $550,000 and less than $1,500,000; the Government will recommend a low-end sentence and restitution of not less than $1,146,271.

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Case 5:23-cr-00087-MHH-HNJ Document 22 Filed 09/13/23 Page 1 of 19 FILED

2023 Sep-13 AM 10:23
U.S. DISTRICT COURT
N.D. OF ALABAMA

IN THE UNITED STATES DISTRICT COURT
FOR THE NORTHERN DISTRICT OF ALABAMA
NORTHEASTERN DIVISION

UNITED STATES OF AMERICA )
) Case No. 5-23-CR-00087-MHH-HNJ
Vv. )

)
JENNIFER CORRINE SCOGGINS )

and JOHN DAVID SCOGGINS )

PLEA AGREEMENT

The Government and the defendant, JOHN DAVID SCOGGINS, hereby

acknowledge the following plea agreement in this case:
PLEA

The defendant agrees to (i) plead guilty to COUNT ONE (1) of the Indictment
filed in the above-numbered and -captioned matter; (11), pay restitution as determined
by the Court; and (ii1) waive certain rights to direct appeal and collateral attack as
outlined in section IV of this agreement. In exchange, the United States Attorney,
acting on behalf of the Government and through the undersigned Assistant United
States Attorney, agrees to (1) dismiss COUNTS TWO (2) through FIVE (5) of the
Indictment as to the defendant, JOHN DAVID SCOGGINS, and (ii) recommend

the disposition specified below, subject to the conditions in section VII.

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TERMS OF THE AGREEMENT

I. MAXIMUM PUNISHMENT

The defendant understands that the maximum statutory punishment that

may be imposed for the crime of Conspiracy to Commit Wire Fraud, in violation of

Title 18, United States Code, Section 1349, as charged in Count One is:

A. — Imprisonment for not more than 20 years;
B. A fine of not more than $250,000.00, or;
C. Both (a and b);
D. Supervised release of not more than three years; and
E, Special Assessment Fee of $100 per count.
Il. FACTUAL BASIS FOR PLEA

The Government is prepared to prove, at a minimum, the following facts at

the trial of this case:

A. Overview of the Paycheck Protection Program (PPP)

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

enacted in March 2020 and designed to provide emergency financial assistance to

Americans suffering from the economic effects of the COVID-19 pandemic. Among

other initiatives, the CARES Act, through the PPP, authorized up to $349 billion in

potentially forgivable loans to small business for payroll, job retention, mortgage

interest, and certain other applicable expenses. Each loan draw had a specific

Af 0
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application process and requirements.

The Small Business Administration (SBA) oversaw the PPP and fully
guaranteed every legitimate PPP loan. The SBA would forgive PPP loans if all
employee retention criteria were met, and the funds were used for eligible expenses
within a designated period as set forth in the PPP. The individual PPP loans,
however, were issued by private, SBA-approved lenders who received and processed
the PPP applications. Thus, the loans were made from the lenders’ own funds.

To apply for a PPP loan, a qualifying business was required to submit a PPP
loan application to an SBA-approved lender. In the PPP loan application (SBA Form
2483), the small business (through its authorized representative) had to verify its
average monthly payroll and the total number of employees. These figures were
used to calculate the amount of money the business was eligible to receive under the
PPP. The maximum PPP loan amount a business could receive was 2.5 times the
business’s average monthly payroll costs, up to $10 million.

The borrower was required to make several affirmative certifications as part
of the PPP application process, including: (1) the business was in operation on
February 15, 2020 and has employees for whom it paid salaries and payroll taxes or
paid independent contractors, (2) the funds would be used to retain workers and

otherwise comply with the fund eligibility restrictions, and (3) the information

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provided in the application and supporting documentation was true and accurate in
all material aspects.

B. Overview of the Scheme

Between approximately February and June 2021, John and Jennifer Scoggins,
husband and wife, applied for and received approximately $1.14 million in
fraudulent PPP loans on behalf of at least four companies, some of which were
nonoperational: Scoggins Construction I LLC, Sawdust Construction, Blue Ladder
Construction, and River Peach Apparel. Jennifer Scoggins attempted to receive
more than $500,000 in additional fraudulent PPP loans, but the lenders denied those
applications. The applications were replete with misrepresentations and supported
by fraudulent bank, payroll, and tax records.

The funds were deposited into PNC Bank and Truist Bank accounts opened
by the Scoggins in the names of the four companies and then moved between the
accounts and into John and Jennifer Scoggins’ personal bank accounts. The
Scoggins used the money to purchase a home and automobiles as well as vacations,
crypto currency, and various personal expenses.

C. The Fraudulent PPP Loan Applications

Be Scoggins Construction I LLC (First Draw): $366,163
The Scoggins submitted a first-draw PPP loan application to Ready Cap

Lending on behalf of Scoggins Construction I LLC on March 29, 2021 (SBA Loan

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# 1482129). The application was completed in the name of Jennifer as owner and
electronically signed by Jennifer listing email jennifer@blueladdercon.com. The
application included a copy of Jennifer’s Alabama driver’s license and DocuSign
confirmation sheets listing Jennifer as the electronic signatory. The application
claimed the company employed 21 individuals in 2020 and an average monthly
payroll (not including the owners) of nearly $150,000, both material
misrepresentations. The application included fraudulent quarterly payroll reports
totaling more than $400,000 per quarter. The application also included several
fraudulent IRS Form 941s and 940s claiming Scoggins Construction I LLC paid
more than $1.6 million to its employees in 2020. According to bank subpoena
returns, the $366,163 PPP loan was deposited into the Scoggins Construction I LLC
account on April 9, 2021. The bank account lists Jennifer Scoggins as signatory.
Both the submission of the PPP loan application and the receipt of the funds
constituted inter-state wires.
2. Scoggins Construction I LLC (Second Draw): $366,163
The Scoggins submitted a second-draw PPP loan application to Texas
National Bank on behalf of Scoggins Construction I LLC on May 23, 2021 (SBA
Loan # 1482129). The application was completed in Jennifer’s name and contained
similar fraudulent supporting tax documentation and misrepresentations on the

application itself, such as Scoggins Construction I LLC employed 21 people and

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received 3Q 2019 gross receipts of nearly $900,000.! However, the second draw
application also contained doctored bank statements attempting to show Scoggins
Construction I LLC carrying a nearly $200,000 checking account balance in 2019 in
an attempt to substantiate the misrepresentations about the business’ alleged gross
receipts and how the pandemic negatively impacted the business.

The Scoggins submitted three months of BBVA bank statements for a
checking account ending 6088 in the name of Scoggins Construction I LLC showing
several in-clearing checks and construction-related expenses. The BBVA bank
statements submitted with the application were doctored, as the account ending 6088
was the Scoggins’ personal checking account with a sustained balance of only a few
hundred dollars. Both the submission of the PPP loan application and the receipt of
the funds constituted inter-state wires.

bs Scoggins Construction I LLC (Second Draw): $366,163

On May 23, 2021, Jennifer Scoggins submitted a second, second-draw PPP
loan application to Ready Cap lending on behalf of Scoggins Construction I LLC.
Ready Cap denied this loan. The application included fraudulent tax forms, bank
statements, and employee records. Jennifer used her true social security number and

included copies of her driver’s license. The submission of the PPP loan application

1 The SBA’s second-draw application forms required applicants to list the 2020 and 2019 Q2 gross receipts to
demonstrate that COVID negatively impacted their business. The first-draw applications did not include this
requirement.

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constituted an inter-state wire.
4. Sawdust Construction (First Draw): $206,402
On March 23, 2021, the Scoggins submitted a first-draw PPP loan application
to Ready Cap on behalf of Sawdust Construction (SBA Loan # 1374260). The
application was completed in John’s name and included a copy of his driver’s
license. John Scoggins electronically signed the loan application. Among the
misrepresentations contained in the application was the claim that Sawdust
employed 10 people and received approximately $1.1 million in gross income in
2020. The application included fraudulent IRS filings and employee payroll
records, such as claims Sawdust Construction paid 12 individuals a quarterly payroll
of $250,000 in Q1 2020. The loan was deposited on April 22, 2021, into a BBVA
business checking account in the name of Sawdust Construction. John Scoggins
opened the account shortly before applying for the loan. The bank account listed
John Scoggins as signatory. Both the submission of the PPP loan application and
the receipt of the funds constituted inter-state wires.
5. River Peach Apparel (First Draw): $207,543
On February 17, 2021, Jennifer Scoggins submitted a first-draw PPP loan
application to Transportation Alliance Bank on behalf of Jennifer Scoggins d/b/a
River Peach Apparel. Jennifer Scoggins electronically signed the application with

email account peachlife@riverpeachapparel.com. She claimed 11 employees and

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an average monthly payroll of $83,017. The application also contained fraudulent
2019 IRS Form 941s, employee payroll records, and order forms pre-dating the
establishment of the business and with USPS tracking numbers resolving to different
destinations than listed. Moreover, Jennifer Scoggins had submitted an EIDL
application on behalf of River Peach Apparel in July 2020 in which she stated that
as of January 1, 2020, River Peach had only one employee. The loan was deposited
into the River Peach Apparel bank account on February 18, 2021. The bank account
listed Jennifer Scoggins as signatory. Both the submission of the PPP loan
application and the receipt of the funds constituted inter-state wires.
6. River Peach Apparel (Second Draw): $207,543

On May 28, 2021, Jennifer Scoggins submitted a second-draw PPP loan
application to Texas National Bank on behalf of Jennifer Scoggins d/b/a River Peach
Apparel. Jennifer Scoggins electronically signed the application with email account
sales@riverpeachapparel.com. The application contained several of the same
misrepresentations, but also contained several fraudulent bank statements, tax forms,
and profit and loss summaries, many of which predated August 2020 when the IRS
issued River Peach its EIN. Texas National Bank ultimately denied the PPP loan.

The submission of the PPP loan application constituted an inter-state wire.

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D. John Scoggins Conspired to Commit Wire Fraud

From in or about February 2021 through in or about June 2021, John Scoggins
did knowingly and intentionally combine, conspire, confederate, and agree together
with his wife and co-Defendant, Jennifer Scoggins, to commit wire fraud. As
outlined above, John Scoggins submitted or caused to be submitted a PPP loan
application containing several material misrepresentations and fraudulent supporting
documentation. John Scoggins received the PPP loan funds via interstate wire
transfer into a bank account owned and controlled by him, co-mingled the loan funds
between and among the account and those owned and controlled by Jennifer
Scoggins, and spent the PPP loan funds on unauthorized uses including a personal
home, automobiles, family vacations, and various personal living expenses.

John Scoggins did not play a minimal role in the conspiracy, as knew he and
his co-Defendant were receiving PPP loans to which they were not legally entitled.
However, he did not possess full knowledge or understanding of the scope and
structure of the enterprise and the activities of his co-Defendant, Jennifer Scoggins,
who organized and led the conspiracy.

* OK
The parties stipulate that for the purposes of sentencing the total foreseeable

loss amount as to defendant John David Scoggins is greater than $550,000 and less

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than $1,500,000. The parties further stipulate that venue is appropriate in the

Northern District of Alabama.

The defendant hereby stipulates that the facts stated above are
substantially correct and that the Court can use these facts in calculating the
defendant’s sentence. The defendant further acknowledges that these facts do
not constitute all the evidence of each and every act that the defendant and/or
any co-conspirators may have committed.

OHN DAVID SCOGGINS” ~ SS

Ill. RECOMMENDED SENTENCE

Subject to the limitations in section VII regarding subsequent conduct and

pursuant to Fed. R. Crim. P. 11(c)(1)(B), the Government will recommend the

following disposition:

A.

That the defendant be awarded a two (2) level reduction in the
defendant’s adjusted offense level, based upon the defendant’s apparent
prompt recognition and affirmative acceptance of personal
responsibility for the defendant’s criminal conduct. The Government
agrees to make a motion pursuant to USSG §3E1.1(b) for an additional
one-level decrease in recognition of the defendant’s prompt notification
to the Government of the intention to enter a plea of guilty. The
Government may oppose any adjustment for acceptance of
responsibility if the defendant: (1) fails to admit each and every item
in the factual stipulation; (2) denies involvement in the offense;
(3) gives conflicting statements about the defendant’s involvement in
the offense; (4) is untruthful with the Court, the Government, or the
United States Probation Officer; (5) obstructs or attempts to obstruct
justice prior to sentencing; (6) engages in any criminal conduct between
the date of this agreement and the date of sentencing; or (7) attempts to
withdraw the defendant’s plea of guilty for any reason other than those
expressly enumerated in the “Waiver of Right to Appeal and Post-

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IV.

Conviction Relief” section of this Plea Agreement;

B. That the defendant be remanded to the custody of the Bureau of Prisons
and incarcerated for a term consistent with the low end of the advisory
United States Sentencing Guideline range as calculated by the Court at
the time of sentencing;

C. That following said term of imprisonment, the defendant be placed on
supervised release for a period to be determined by the Court, subject
to the Court’s standard conditions of supervised release;

D. That the defendant be required to pay restitution to all the victims of the
defendant’s crimes, specifically the United States Small Business
Administration, in an amount not less than $1,146,271;

E. That the defendant be required to pay a fine in accordance with the
sentencing guidelines should the Court determine that the defendant has
the ability to pay a fine, said amount due and owing as of the date

sentence is pronounced, with any outstanding balance to be paid in full
by the expiration of the term of supervised release; and,

F, That the defendant pay a special assessment of $100.00, said amount
due and owing as of the date sentence is pronounced.

WAIVERS

A. STATUTE OF LIMITATIONS WAIVER

In consideration of the recommended disposition of this case, I, JOHN
DAVID SCOGGINS, hereby understand, acknowledge, and agree that if this
plea agreement is set aside for any reason, I will not assert any defense based
on any applicable statute of limitations or the Speedy Trial Act, 18 U.S.C.

§ 3161, et seg., that includes the passage of time from and including the date of

7s
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this plea agreement until and including the date of entry of any order setting
this plea agreement aside.

B. RIGHT TO APPEAL AND POST-CONVICTION RELIEF

In consideration of the recommended disposition of this case, I, JOHN
DAVID SCOGGINS, hereby waive and give up my right to appeal my
conviction and/or sentence in this case, as well as any fines, restitution, and
forfeiture orders, the Court might impose. Further, I waive and give up the
right to challenge my conviction and/or sentence, any fines, restitution,
forfeiture orders imposed or the manner in which my conviction and/or
sentence, any fines, restitution, and forfeiture orders were determined in any
post-conviction proceeding, including, but not limited to, a motion brought
under 28 U.S.C. § 2255, and any argument that (1) the statute(s) to which I am
pleading guilty is or are unconstitutional or (2) the admitted conduct does not
fall within the scope of the statute(s).

The defendant reserves the right to contest in an appeal or post-
conviction proceeding(s) the following:

1. Any sentence imposed in excess of the applicable statutory
maximum sentence(s);

2. Any sentence imposed in excess of the Guidelines range
determined by the Court at the time sentence is imposed; and

3. Ineffective assistance of counsel.

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The defendant acknowledges that before giving up these rights, the
defendant discussed the United States Sentencing Guidelines and their
application to the defendant’s case with the defendant’s attorney, who
explained them to the defendant’s satisfaction. The defendant further
acknowledges and understands that the Government retains its right to appeal
where authorized by statute.

I, JOHN DAVID SCOGGINS, hereby place my signature on the line
directly below to signify that I fully understand the foregoing paragraphs, and

that I am knowingly and voluntarily entering into this waiver.

V. UNITED STATES SENTENCING GUIDELINES
The defendant’s counsel has explained to the defendant, that in light of the
United States Supreme Court’s decision in United States v. Booker, the federal
sentencing guidelines are advisory in nature. Sentencing is in the Court’s discretion
and is not required to be within the guideline range. The defendant agrees that,
pursuant to this agreement, the Court may use facts it finds by a preponderance of
the evidence to reach an advisory guideline range, and the defendant explicitly

waives any right to have those facts found by a jury beyond a reasonable doubt.

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VI. AGREEMENT NOT BINDING ON COURT

The defendant fully and completely understands and agrees that it is the
Court’s duty to impose sentence upon the defendant and that any sentence
recommended by the Government is NOT BINDING UPON THE COURT, and
that the Court is not required to accept the Government’s recommendation. Further,
the defendant understands that if the Court does not accept the Government’s
recommendation, the defendant does not have the right to withdraw the guilty plea.

Vil. VOIDING OF AGREEMENT

The defendant understands that if the defendant (a) violates any federal, state,
or local law or any condition of pretrial release after entering into this plea
agreement, (b) moves the Court to accept a plea of guilty in accordance with, or
pursuant to, the provisions of North Carolina v. Alford, 400 U.S. 25 (1970),
(c) tenders a plea of nolo contendere to the charges, (d) violates any other term of
this plea agreement, and/or (e) does or says anything that is inconsistent with the
acceptance of responsibility, the plea agreement will become NULL and VOID at
the election of the United States, and the United States will not be bound by any of
the terms, conditions, or recommendations, express or implied, which are contained
herein. Further, such election will not entitle the defendant to withdraw a previously

entered plea.

Page 14 of 19 Defendant’s Initials_ 77
Vill. OTHER DISTRICTS AND JURISDICTIONS
The defendant understands and agrees that this agreement DOES NOT BIND
any other United States Attorney in any other district, or any other state or local
authority.
IX. COLLECTION OF FINANCIAL OBLIGATION
To facilitate the collection of financial obligations to be imposed in
connection with this prosecution, the defendant agrees to:

e fully disclose all assets in which the defendant has any interest or over which
the defendant exercises control, directly or indirectly, including those held by
a spouse, nominee or other third party;

e promptly submit a completed financial statement to the United States
Attorney’s Office, in a form that it provides and as it directs;

e identify all assets over which the defendant exercises or exercised control,
directly or indirectly, within the past five years, or in which the defendant has
or had during that time any financial interest;

e take all steps as requested by the Government to obtain from any other parties
by any lawful means any records of assets owned at any time by the defendant;

e undergo any polygraph examination the Government may choose to
administer concerning such assets and to provide and/or consent to the release

of the defendant’s tax returns for the previous five years.

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The defendant further agrees that the above information, as well as any of the
defendant’s financial statements and disclosures, will be complete, accurate, and
truthful. Finally, the defendant expressly authorizes the United States Attorney’s
Office to obtain a credit report on the defendant to evaluate the defendant’s ability
to satisfy any financial obligation imposed by the Court.

X. AGREEMENT REGARDING RELEVANT CONDUCT AND
RESTITUTION

As part of the defendant’s plea agreement, the defendant admits to the above
facts associated with the charges and relevant conduct for any other acts. The
defendant understands and agrees that the relevant conduct contained in the factual
basis will be used by the Court to determine the defendant’s range of punishment
under the advisory sentencing guidelines. The defendant admits that all the crimes
listed in the factual basis are part of the same acts, scheme, and course of conduct.
This agreement is not meant, however, to prohibit the United States Probation Office
or the Court from considering any other acts and factors, which may constitute or
relate to relevant conduct. Additionally, if this agreement contains any provisions
providing for the dismissal of any counts, the defendant agrees to pay any
appropriate restitution to each of the separate and proximate victims related to those
counts should there be any and waives objection to the inclusion of that restitution

in any order issued by the Court.

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XI. TAX, FORFEITURE AND OTHER CIVIL/ADMINISTRATIVE
PROCEEDINGS

Unless otherwise specified herein, the defendant understands and
acknowledges that this agreement does not apply to or in any way limit any pending
or prospective proceedings related to the defendant’s tax liabilities, if any, or to any
pending or prospective forfeiture or other civil or administrative proceedings.

XII. IMMIGRATION STATUS

The defendant recognizes that pleading guilty may have consequences with
respect to the defendant’s immigration status if the defendant is not a citizen of the
United States. Under federal law, a broad range of crimes are removable offenses,
including the offense(s) to which the defendant is pleading guilty. The defendant’s
guilty plea and conviction make it practically inevitable and a virtual certainty that
the defendant will be removed or deported from the United States if the defendant is
not a citizen of the United States. Removal and other immigration consequences are
the subject of a separate proceeding, however; and the defendant understands that
no one, including her attorney or the district court, can predict to a certainty the effect
of her conviction on her immigration status. Understanding all of this, the defendant
nevertheless affirms that the defendant wants to plead guilty regardless of any
immigration consequences that plea may entail, even if the consequence is automatic

removal from the United States.

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XIII. DEFENDANT’S ACKNOWLEDGEMENT

I have read and understand the provisions of this plea agreement consisting of
nineteen (19) pages. I have discussed the case and my constitutional and other rights
with my lawyer. I am satisfied with my lawyer’s representation in this case. I
understand that by pleading guilty, I will be waiving and giving up my right to
continue to plead not guilty, to a trial by jury, to the assistance of counsel at that trial,
to confront, cross-examine, or compel the attendance of witnesses, to present
evidence on my behalf, to maintain my privilege against self-incrimination, and to
the presumption of innocence. I agree to enter my plea as indicated above on the
terms and conditions set forth herein.

NO PROMISES OR REPRESENTATIONS OTHER THAN THOSE IN

THE AGREEMENT HAVE BEEN MADE TO ME BY THE

PROSECUTOR, OR BY ANYONE ELSE, NOR HAVE ANY THREATS

BEEN MADE OR FORCE USED TO INDUCE ME TO PLEAD
GUILTY.

I further state that I have not had any drugs, medication, or alcohol within the

past 48 hours except as stated here:

[ understand that this plea agreement will take effect and will be binding as to
the Parties only after all necessary signatures have been affixed hereto.
I have personally and voluntarily placed my initials on every page of this plea

agreement and have signed the signature line below to indicate that I have read,

44

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understand, and approve all the provisions of this plea agreement, both individually

and as a total binding agreement.

“DATE J OHN DAVID SCOGGINS
Defendant

XIV. COUNSEL’S ACKNOWLEDGMENT
I have discussed this case with my client in detail and have advised my client
of all my client’s rights and all possible defenses. My client has conveyed to me that
my client understands this plea agreement and consents to all its terms. I believe the
plea and disposition set forth herein are appropriate under the facts of this case and
are in accord with my best judgment. I concur in the entry of the plea agreement on

the terms and conditions set forth mae rs >

DATE / JERRY S. BARCLAY
Defendant’s Counsel

XV. GOVERNMENT’S ACKNOWLEDGMENT
I have reviewed this matter and this plea agreement and concur that the plea

and disposition set forth herein are appropriate and are in the interests of justice.

PRIM F. ESCALONA
United States Attorney

DATE JONATHAN “JACK” HARRINGTON
Assistant United States Attorney

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