Redacted Indictment — USA v. Hunt (No. 1:25-cr-00044, Dkt. 2, E.D. Mo.)

Summary

An indictment in United States of America v. Jai Dawness Hunt, Case 1:25-cr-00044-SEP, in the United States District Court for the Eastern District of Missouri, Southeastern Division, filed March 4, 2025 as Doc. #: 2. Count I charges a false statement to a financial institution under 18 U.S.C. § 1014 and Count II charges wire fraud under 18 U.S.C. § 1343. The grand jury charges that on or about April 22, 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 2019 Schedule C. It charges that the lender transferred $20,000.00 to the defendant's bank account. The forfeiture allegations seek a sum of at least $20,000.00; the signature blocks name United States Attorney Sayler A. Fleming and Assistant United States Attorney Tim J. Willis.

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“Redacted Indictment — USA v. Hunt (No. 1:25-cr-00044, 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-d0b89aa16c/, SHA-256 346333db63b86480d79a9b874806e48a21141620656dc37b7c27328b231b552f.

Full text

Case: 1:25-cr-00044-SEP Doc. #: 2 Filed: 03/04/25 Page: 1 of 7 PageID #: 9

FILED

MAR O' 4 2025
IN THE UNITED STATES DISTRICT COURT
U. S. DISTRICT COURT
FOR THE EASTERN DISTRICT OF MISSOURI EASTERN DISTR ICT OF MO
SOUTHEASTERN DIVISION CAPE GIRARDEAU

UNITED STATES OF AMERICA, )
)
Plaintiff, )
)
vs. ) 1:25CR00044-SEP-ACL
)
JAi DAWNESS 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. Jai Dawness Hunt, a defendant herein, was a resident of Caruthersville, Pemiscot County

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

2. Jai 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 government that provides support 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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Case: 1:25-cr-00044-SEP Doc. #: 2 Filed: 03/04/25 Page: 2 of 7 PageID #: 10

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 certify: (a) that the small

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

and (c) the nun1ber 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 supporting their payroll expenses.

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

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

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

loan, the SBA would purchase the bonower's debt from the lending finai1cial institution and

assume the responsibility for paying back the loan.

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Case: 1:25-cr-00044-SEP Doc. #: 2 Filed: 03/04/25 Page: 3 of 7 PageID #: 11

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

including payroll costs, mmigage 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. 11 In that same application, the borrower must also certify

that 11 [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. 11

9. 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.

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

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

Benwmih processed applications for PPP loai1s that were submitted through an internet-based

web portal, which affected interstate commerce.

The Scheme to Defraud

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

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

12. On or about April 22, 2021 , in the Southeastern Division of the Eastern District of Missouri

and elsewhere, the defendant, Jai Hunt, knowingly made a false statement to Benworth Capital

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Case: 1:25-cr-00044-SEP Doc. #: 2 Filed: 03/04/25 Page: 4 of 7 PageID #: 12

Partners, 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

13. It was a part of the scheme that, on or about April 22, 2021 , Jai Hunt submitted and caused to

be submitted a fraudulent PPP loan application on behalf of Jai Hunt, which falsely stated:

a) That Jai Hunt was the owner I 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.

14. Further, Jai 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 2019 which falsely represented specified income and expenses.

When in truth and fact, there was no such business and Jai Hunt had not obtained the
income listed, nor incurred the expenses claimed, and J ai 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)

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

16. On or about April 22, 2021 , in the Southeastern Division of the Eastern District of Missouri

and elsewhere, the defendant, Jai Hunt voluntarily and intentionally devised or participated in a

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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 Jai 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.

17. It was a part of the scheme that, on or about April 22, 2021 , Jai Hunt submitted and caused to

be submitted a fraudulent PPP loan application on behalf of Jai Hunt, which falsely stated:

a) That Jai 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.

18. Further, Jai 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 2019

which falsely represented specified income and expenses.

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

electronically transfer $20,000.00 to a bank account of Jai Hunt.

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Forfeiture Allegations

The Grand Jury fmiher 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 the total value of the

prope1iy, real or personal, constituting or derived from any proceeds traceable to such violation,

which is at least $20,000.00.

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 transfened 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 prope1iy which cannot be divided without
difficulty,
the United States of America will be entitled to the forfeiture of substitute property

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

A TRUE BILL

Foreperson

SAYLER A. FLEMING
United States Attorney

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. . Case: 1:25-cr-00044-SEP Doc. #: 2 Filed: 03/04/25 Page: 7 of 7 PageID #: 15

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

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