Redacted Indictment — USA v. Hunt (No. 1:25-cr-00047, Dkt. 2, E.D. Mo.)
Summary
An indictment in United States of America v. Dawnikia Bruceatte Hunt, a/k/a Dawnika Hunt, Case 1:25-cr-00047-CMS, 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 Section 1014 and Count II charges wire fraud under 18 U.S.C. § 1343. The grand jury charges that on or about May 1, 2021 the defendant caused a PPP loan application to be submitted to Fountainhead Small Business Finance, LLC claiming a small business in operation on February 15, 2020, supported by a false 2019 Schedule C. It charges that the lender transferred $19,960.00 to the defendant's bank account. The forfeiture allegations seek at least $19,960.00; 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-00047, 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-e1a05db18a/
, SHA-256 a5bee67c9ed588fd4462b43ed070c732d292868e524502834ca068477b66fcfd.Full text
Case: 1:25-cr-00047-CMS Doc. #: 2 Filed: 03/04/25 Page: 1 of 7 PageID #: 9
FILED
IN THE UNITED STATES DISTRICT COURT MAR O4 2025
FOR THE EASTERN DISTRICT OF MISSOURI U. S. DISTRICT COUR1
SOUTHEASTERN DIVISION EASTERN DISTRICT Of W
CAPF Gl~i-R f,..
UNITED STATES OF AMERICA, )
)
Plaintiff, )
)
vs. ) 1:25CR00047-SEP-ACL
)
DAWNIKIA BRUCEATTE HUNT, ) Title 18, U.S.C. § 1014.
a/k/a, Dawnika Hunt, ) 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. Dawnikia Bruceatte Hunt, the defendant herein, was a resident of Caruthersville, Pemiscot
County
Missouri, within the Southeastern Division of the Eastern District of Missouri.
2. Dawnikia 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
recove1y after disasters.
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4. The Coronavirus Aid, Relief, and Economic Security ("CARES") Act, Pub. L. No.
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-1 9 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 ce1iain affirmative
ce1tifications to obtain the PP_P 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 certifications were used to calculate the amotmt 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 participating lender. If a PPP loan
application was approved, the paiiicipating 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 bonower's debt from the lending financial institution and
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assume the responsibility for paying back the loan.
8. PPP loan funds were required to be used on certain permissible expenses,
including payroll costs, mortgage interest, rent, and utilities for the business. In the PPP loan
application (SBA Form 2483), the borrower must ce1iify 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."
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 p01iion of the loan toward
payroll expenses.
10. Fountainhead Small Business Finance, LLC (Fountainhead), a financial institution
headquartered in Lake Mary, Florida, was a paiiicipating lender and issued PPP loans guai·anteed
by the SBA. Fountainhead processed applications for PPP loans that were submitted through an
internet-based web po1ial, which affected interstate commerce.
The Scheme to Defraud
COUNTI
False Statement (18 U.S.C. § 101 4)
11. Paragraphs 1-10 are realleged and incorporated by reference as if fully set forth herein.
12. On or about May 1, 2021 , in the Southeastern Division of the Eastern District of Missouri and
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elsewhere, the defendant, Dawnikia Hunt, knowingly made a false statement to Fountainhead
Small Business Finance, LLC, a financial institution, for the purpose of influencing the action of
Fountainhead Small Business Finance, 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 May 1, 2021 , Dawnikia Hunt caused to be
submitted a fraudulent PPP loan application on behalf of Dawnikia Hunt, which falsely stated:
a) That Dawnikia 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, Dawnikia 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, claiming specified amounts of income and expenses.
When in truth and fact, there was no such business and Dawnikia Hunt had not obtained
the gross income listed, nor incurred the expenses claimed, and Dawnikia 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.
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16. On or about May 1, 2021 , in the Southeastern Division of the Eastern District of Missouri and
elsewhere, the defendant, Dawnikia 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 Dawnikia Hunt, in furtherance of the scheme, and the scheme affected Fountainhead
Small Business Finance, 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 May 1, 2021, Dawnikia Hunt submitted and caused
to be submitted a fraudulent PPP loan application on behalf of Dawnikia Hunt, which falsely
stated:
a) That Dawnikia 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, Dawnikia 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 amounts of income and expenses.
When in truth and fact, there was no such business and Dawnikia Hunt had not obtained
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the gross income listed, nor incurred the expenses claimed and Dawnikia 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 $19,960.00 to a bank account ofDawnikia Hunt.
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 prope1iy 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
property, real or personal, constituting or derived from any proceeds traceable to such violation,
which is at least $19,960.00.
If any of the prope1iy 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 paiiy;
c. has been placed beyond the jurisdiction of the comi;
d. has been substantially diminished in value; or
e. has been commingled with other prope1iy which caimot be divided without
difficulty,
the United States of America will be entitled to the fo1feiture of substitute property
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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