Redacted Indictment — USA v. Hunt (No. 1:25-cr-00045, Dkt. 2, E.D. Mo.)

Summary

An indictment in United States of America v. Victoria Natasha Hunt, Case 1:25-cr-00045-SNLJ, in the United States District Court for the Eastern District of Missouri, filed March 4, 2025 as Doc. #: 2. Count I charges a false statement to a financial institution under Title 18, United States Code, Section 1014, and Count II charges wire fraud under Section 1343. The grand jury charges that on or about April 30, 2021 the defendant submitted a PPP loan application to Benworth Capital Partners, LLC claiming a small business in operation on February 15, 2020, supported by a false 2020 Schedule C. It charges that the lender transferred $19,870.00 to the defendant's bank account. The forfeiture allegations seek a sum of at least $19,870.00; the signature blocks name United States Attorney Sayler A. Fleming and Tim J. Willis.

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“Redacted Indictment — USA v. Hunt (No. 1:25-cr-00045, Dkt. 2, E.D. Mo.).” Original at ecf.moed.uscourts.gov. Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/redacted-indictment-usa-v-hunt-dkt-2-e-d-mo-d05f20244b/, SHA-256 8814964512a6212479b3b2776993ef28c819d298e929d18495f9ea99b78189e5.

Full text

Case: 1:25-cr-00045-SNLJ Doc. #: 2 Filed: 03/04/25 Page: 1 of 7 PageID #: 9

FILED

MAR O4 2025
IN THE UNITED STATES DISTRICT COURT
U. S. DISTRICT COURT
FOR THE EASTERN DISTRICT OF MISSOURI EASTERN DISTRICT OF MO
SOUTHEASTERN DIVISION CAPE GIRARDEAU

UNITED STATES OF AMERICA, )
)
Plaintiff, )
)
vs. ) 1:25CR00045-SNLJ-ACL
)
VICTORIA NATASHA HUNT, ) Title 18, U.S .C. § 1014.
) Title 18, U.S.C. § 1343.
) Forfeiture allegations.
Defendant. )

INDICTMENT

THE GRAND JURY CHARGES THAT:

At all times material to this Indictment, unless otherwise specified below:

1. Victoria Hunt, the defendant herein, was a resident of Caruthersville, Pemiscot County

Missouri, within the Southeastern Division of the Eastern District of Missouri.

2. Victoria Hunt did not own or operate a business registered or incorporated within the

State of Missouri which was in operation on February 15, 2020.

The Paycheck Protection Program

3. The United States Small Business Administration ("SBA") is an executive-branch

agency of the United States govenunent that provides supp01i to entrepreneurs and small

businesses. The mission of the SBA is to maintain and strengthen the nation's economy by

enabling the establishment and viability of small businesses and by assisting in economic

recovery after disasters.

4. The Coronavirus Aid, Relief, and Economic Security ("CARES") Act, Pub. L. No.

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116-136, 134 Stat. 281 (2020), is a federal law that was enacted in or around March 2020 to

provide emergency financial assistance to the millions of Americans suffering the economic

impact caused by the COVID-19 pandemic. One source of relief provided for in the CARES Act

was the authorization of forgivable loans to small businesses for job retention and certain other

expenses through the Paycheck Protection Program ("PPP"). The purpose of loans issued under

the PPP was to enable small businesses suffering from the economic downturn to continue to pay

salary, wages and to provide benefits, such as health insurance coverage, to their employees.

5. To obtain a PPP loan, a qualifying business was required to submit a PPP loan

application, signed by an authorized representative of the business. The PPP loan application

required the business to acknowledge the program rules and make certain affirmative

certifications to obtain the PPP loan. ln the PPP loan application (SBA Form 2483), the small

business (through its authorized representative) was required to ce1iify: (a) that the small

business was in operation on February 15, 2020; and (b) the average monthly payroll expenses;

and (c) the number of employees. These ce1iifications were used to calculate the amount of

money the small business was eligible to receive under the PPP. In addition, businesses applying

for PPP loans were required to submit documentation suppo1iing their payroll expenses.

6. A PPP loan application was then processed by a paiiicipating lender. If a PPP loai1

application was approved, the participating lender funded the loan using its own monies, which

were then guai·anteed by the SBA. Generally, in the event that the borrower defaulted on a PPP

loan, the SBA would purchase the borrower's debt from the lending financial institution and

assume the responsibility for paying back the loan.

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7. PPP loan funds were required to be used on ce1iain permissible expenses,

including payroll costs, mortgage interest, rent, and utilities for the business. In the PPP loan

application (SBA Form 2483), the borrower must certify that "[a]ll SBA loan proceeds will be

used only for business-related purposes as specified in the loan application and consistent with

the Paycheck Protection Program Rule." In that same application, the borrower must also certify

that "[t]he funds will be used to retain workers and maintain payroll or make mortgage interest

payments, lease payments, and utility payments, as specified under the Paycheck Protection

Program Rule."

8. Under the applicable PPP rules and guidance, the interest and principal on the

PPP loan was eligible for forgiveness if the business spent the loan proceeds on these authorized

expense items within a designated period of time and used a certain portion of the loan toward

payroll expenses.

9. Benworth Capital Partners, LLC (Benw01ih), a financial institution headquaiiered in

Coral Gables, Florida, was a participating lender and issued PPP loans guarai1teed by the SBA.

Hai·vest processed applications for PPP loans that were submitted through ai1 internet-based web

portal, which affected interstate commerce.

The Scheme to Defraud

COUNTI
False Statement (18 U.S .C. § 1014)

10. Paragraphs 1- 9 are realleged and incorporated by reference as if fully set forth herein.

11. On or about April 30, 2021 , in the Southeastern Division of the Eastern District of

Missouri and elsewhere, the defendant, Victoria Hunt, knowingly made a false statement to

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Benworth Capital Paiiners, LLC, a financial institution, for the purpose of influencing the action

of Benworth Capital Partners, LLC upon an application for a SBA backed PPP loan, in violation

of Title 18, United States Code, Section 1014 and punishable under Title 18, United States Code,

Section 1014.

Manner and Means

12. It was a part of the scheme that, on or about April 30, 2021 , Victoria Hunt submitted and

caused to be submitted a fraudulent PPP loan application on behalf of Victoria Hunt, which falsely

stated:

a) That Victoria Hunt was the owner / operator of a small business that was in operation in
Missouri on February 15, 2020.

b) That any funds received by way of a PPP loan would be spent on permissible expenses,
such as payroll costs, mortgage interest, rent and utilities for the business which she
claimed.

13. Further, Victoria Hunt knowingly submitted and caused to be submitted certain documents

in support of the fraudulent PPP loan application, including a materially false and fraudulent

Internal Revenue Service (IRS) Schedule C (Form 1040) Profit or Loss From Business form

(Schedule C) for 2020 which falsely represented a gross income and business expenses.

When in truth and fact, there was no such business and Victoria Hunt had not obtained the
gross income listed, nor incurred the expenses claimed, and Victoria Hunt did not spend the
proceeds of the loan in a manner consistent with the rules of the program.

COUNT II
Wire Fraud (18 U.S .C. § 1343)

14. Paragraphs 1- 9 are realleged and incorporated by reference as if fully set forth herein.

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15. On or about April 30, 2021, in the Southeastern Division of the Eastern District of

Missouri and elsewhere, the defendant, Victoria Hunt voluntarily and intentionally devised or

participated in a scheme to obtain money by means of material false representations, namely the

submission of a fraudulent PPP loan application, with the intent to defraud, and the defendant used,

or caused to be used an interstate wire communication, that is the electronic submission of a

fraudulent loan application via the internet, for the purpose of obtaining an electronic deposit of

funds into a bank account of Victoria Hunt, in furtherance of the scheme, and the scheme affected

Benworth Capital Partners, LLC, a financial institution, in violation of Title 18 United States Code,

Section 1343 and punishable under Title 18, United States Code, Section 1343.

16. It was a part of the scheme that, on or about April 30, 2021 , Victoria Hunt submitted

and caused to be submitted a fraudulent PPP loan application on behalf of Victoria Hunt, which

falsely stated:

a) That Victoria Hunt was the owner / operator of a small business that was in operation in
Missouri on February 15, 2020.

b) That any funds received by way of a PPP loan would be spent on permissible expenses,
such as payroll costs, mortgage interest, rent and utilities for the business which she
claimed.

17. Further, Victoria Hunt submitted and caused to be submitted certain documents in

support of the fraudulent PPP loan application, including a materially false and fraudulent Internal

Revenue Service (IRS) Schedule C (Form 1040) Profit or Loss From Business form (Schedule C)

for 2020 which falsely represented a gross income and business expenses.

When in truth and fact, there was no such business and Victoria Hunt had not obtained the
gross income listed, nor incurred the expenses claimed and Victoria Hunt did not spend the
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proceeds of the loan in a manner consistent with the rules of the program.
18. As a result of the materially false and fraudulent application for a PPP loan, the

lender did electronically transfer $19,870.00 to a bank account of Victoria Hunt.

Forfeiture Allegations

The Grand Jury fmther finds by probable cause that:

Pursuant to Title 18, United States Code, Section 982(a)(2)(A) and (a)(3)(F), upon

conviction of an offense in violation of Title 18, United States Code, Section 1014 and/or

Section 1343, as set forth in the Indictment, the defendant shall forfeit to the United States of

America any property constituting, or derived from, proceeds obtained, directly or indirectly, as

a result of such violation. Subject to forfeiture is a sum of money equal to tl1e total value of the

prope1ty, real or personal, constituting or derived from any proceeds traceable to such violation,

which is at least $19,870.00.

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 transfen-ed or sold to, or deposited with, a third party;
c. has been placed beyond the jurisdiction of the comt;
d. has been substantially diminished in value; or
e. has been c01mningled with other property which cannot be divided without
difficulty,
the United States of America will be entitled to the forfeiture of substitute prope1ty

pursuant to Title 21 , United States Code, Section 853(p).

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A TRUE BILL

Foreperson

SAYLER A. FLEMING
United States Attorney

Tim J. Willis, # 62428MO
Assistant United States Attorney

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