United States’ Sentencing Memorandum, United States v. Verlynn Horne (M.D. Fla., August 12, 2026)

Summary

The United States' Sentencing Memorandum in United States of America v. Verlynn Horne, Case No. 6:25-cr-161-JSS-NWH, in the U.S. District Court for the Middle District of Florida, Orlando Division, filed August 12, 2026 as Document 87. The government seeks 51 months of imprisonment, the high end of a guidelines range of 41 to 51 months. It recounts PPP loans of $175,000 to Platinum Status Consulting Inc. and $162,915 to Good Neighbor Tax Service Inc. on false applications, and states the defendant helped at least 35 other entities and individuals obtain $4,476,437, receiving $2,180,015 of it and $2,517,930 in total. It adds that no tax returns reporting income were filed for 2020 or 2021, leaving $766,707.20 owed to the IRS, and notes the guilty pleas to Counts Six and Twelve on April 7, 2026. It is signed by Assistant United States Attorney Diane S. Hu.

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Case 6:25-cr-00161-JSS-NWH      Document 87      Filed 08/12/26   Page 1 of 6 PageID 250



                       UNITED STATES DISTRICT COURT
                        MIDDLE DISTRICT OF FLORIDA
                            ORLANDO DIVISION

  UNITED STATES OF AMERICA

       v.                                         CASE NO. 6:25-cr-161-JSS-NWH

  VERLYNN HORNE

              UNITED STATES’ SENTENCING MEMORANDUM

       The United States of America seeks a sentence of 51 months of imprisonment

 for the defendant Verlynn Horne, which is on the high end of her guidelines range.

 For the reasons below, such a sentence is sufficient but not greater than necessary to

 comply with the purposes of 18 U.S.C. § 3553(a).

                                   BACKGROUND

       During the summer of 2020, the defendant fraudulently applied for and

 obtained multiple COVID-19 Economic Injury Disaster Loans (“EIDLs”) and

 Paycheck Protection Program (“PPP”) loans. See ECF No. 65 at 18–19.

       On July 23, 2020, the defendant fraudulently applied for a PPP loan on behalf

 of Platinum Status Consulting Inc. (“PSC”). Id. at 18. The defendant was the

 Chief Executive Officer of PSC, which was incorporated in Florida on June 9, 2020,

 after the COVID-19 pandemic began. Id. PSC had no business operations or

 payroll prior to the pandemic. Id. The application falsely claimed that PSC had

 eleven employees and a monthly payroll of $70,000. Id. In support of the

 application, the defendant submitted false documents, including a false 2019 tax

 return and false Form 1099-MISCs. Id. at 19. One of the Form 1099-MISCs
Case 6:25-cr-00161-JSS-NWH       Document 87      Filed 08/12/26   Page 2 of 6 PageID 251



 falsely represented that E.L. was an employee of PSC. Id. However, during an

 interview with law enforcement, E.L. stated that she was not an employee of PSC

 and had not received any income from PSC. Id. Fifth Third Bank granted the

 application and transferred $175,000 into a PSC bank account controlled by the

 defendant. Id.

       On August 3, 2020, the defendant fraudulently applied for a PPP loan on

 behalf of Good Neighbor Tax Service Inc. (“GNTS”). Id. The defendant was the

 Chief Financial Officer of GNTS, which was incorporated before the COVID-19

 pandemic but had no business operations, employees, or payroll. Id. In July 2020,

 after the pandemic began, the defendant reinstated GNTS, listing herself and her

 spouse as officers. Id. The application falsely claimed that GNTS had $941,152 in

 gross receipts, $56,220 in net income, and twelve employees with a monthly payroll

 of $65,166. Id. In support of the application, the defendant submitted false

 documents, including a false 2019 tax return. Id. Fifth Third Bank granted the

 application and transferred $162,915 into a GNTS bank account controlled by the

 defendant. Id.

       The defendant also helped prepare and submit fraudulent COVID-19 loan

 applications on behalf of at least 35 other entities and individuals, who collectively

 received $4,476,437 in total. Id. at 18. In exchange for her work on the other

 individuals’ fraudulent applications, the defendant received a cut of their loan

 proceeds, totaling $2,180,015. Id. As a result of her scheme, the defendant received




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 a total of $2,517,930, and used a portion of those funds to pay for a residence in

 Winter Garden, Florida. Id. at 18, 20.

       Despite receiving over $2.5 million in COVID-19 loan funds, the defendant

 did not submit a tax return for herself or her entities that reported income for the

 years 2020 or 2021. Id. at 21. For those two years, the defendant owed a total of

 $766,707.20 to the Internal Revenue Service (“IRS”). ECF No. 85 (Presentence

 Investigation Report (“PSR”)) ¶ 40.

       On June 4, 2025, a federal grand jury returned a thirteen-count indictment

 charging the defendant with nine counts of wire fraud, in violation of 18 U.S.C.

 § 1343 (Counts One through Nine); one count of aggravated identity theft, in

 violation of 18 U.S.C. § 1028A(a)(1) (Count Ten); one count of transactional money

 laundering, in violation of 18 U.S.C. § 1957 (Count Eleven); and two counts of

 willful failure to file tax returns, in violation of 26 U.S.C. § 7203 (Counts Twelve and

 Thirteen) (the “Indictment”). ECF No. 1.

       On April 7, 2026, the defendant pleaded guilty to Counts Six and Twelve of

 the Indictment pursuant to a plea agreement. ECF Nos. 65, 67. As noted in the

 PSR, if the defendant were convicted of Count Ten of the Indictment, she would

 have faced a mandatory consecutive two-year term of imprisonment. PSR ¶ 88.

       The Court adjudicated the defendant guilty on April 23, 2026. ECF No. 73.

       The defendant’s sentencing hearing is set for August 17, 2026. ECF No. 84.




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                                     ARGUMENT

       The United States of America seeks a sentence of 51 months of imprisonment,

 which is on the high end of the defendant’s guidelines range of 41 to 51 months.

 PSR ¶ 87. Under 18 U.S.C. § 3553(a), the factors that the Court should consider

 when imposing a sentence include:

       (1) the nature and circumstances of the offense and the history and
           characteristics of the defendant;

       (2) the need for the sentence imposed—

              (A) to reflect the seriousness of the offense, to promote respect
              for the law, and to provide just punishment for the offense;

              (B) to afford adequate deterrence to criminal conduct;

              (C) to protect the public from further crimes of the defendant;
              and

              (D) to provide the defendant with needed educational or
              vocational training, medical care, or other correctional
              treatment in the most effective manner . . . .

 18 U.S.C. § 3553(a)(1)–(2).

       First, the nature and circumstances of the defendant’s offenses are serious.

 The defendant took advantage of and profited from the Small Business

 Administration’s COVID-19 economic assistance programs, which were intended to

 help businesses and employees negatively impacted by the pandemic. The

 defendant not only submitted multiple fraudulent loan applications on behalf of her

 own non-operational businesses, but she also helped prepare and submit fraudulent

 applications on behalf of at least 35 other entities and individuals, in exchange for a

 portion of the loan proceeds. These applications listed false figures regarding the
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 businesses’ number of employees, income, and expenses, and included falsified tax

 documents. In particular, the defendant’s application on behalf of PSC included a

 tax document falsely representing that an individual, E.L., was an employee. But

 E.L. told law enforcement that she was not a PSC employee, had not received any

 income from PSC, and was not aware that her identity had been used in connection

 with a PPP loan application.

       In sum, the defendant’s role in the submission of numerous fraudulent loan

 applications—which involved the use of at least one individual’s personal identifiable

 information without their authorization—resulted in the disbursement of over $4.8

 million in loan proceeds to the defendant and her clients. See PSR ¶ 40. Despite

 not having any real business entitled to COVID-19 relief, the defendant in essence

 created a business out of filing fraudulent loan applications, as she personally

 received over $2.5 million from the scheme. These millions of taxpayer dollars were

 required to be spent on legitimate businesses’ payroll and other expenses. Instead,

 the defendant used a portion of her proceeds to purchase a home for her and her

 spouse. Furthermore, the defendant failed to file tax returns or report any of her

 earnings from her fraudulent scheme for the years 2020 and 2021. The defendant

 owed but failed to pay the IRS $766,707.20, causing a significant loss to another

 federal government agency.

       With respect to the defendant’s history and characteristics, the government

 recognizes that the defendant is the caretaker of her fifteen-year-old son, and that she

 has physical and mental health issues. Those physical health issues were the

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 primary basis for the numerous continuances of trial in this case. The government

 also acknowledges that the defendant has no criminal history and ultimately

 accepted responsibility, as reflected in the two-level adjustment for being a zero-point

 offender and three-level adjustment for acceptance of responsibility. PSR ¶¶ 55–57.

 However, taking everything into consideration—particularly the circumstances of the

 offense involving the unauthorized use of another person’s personal information, and

 resulting in a significant loss to two government agencies—a sentence of 51 months

 is warranted. Such a sentence is sufficient, but not greater than necessary, to

 comply with the purposes of 18 U.S.C. § 3553(a)—specifically, to reflect the

 seriousness of the defendant’s offense, promote respect for the law, provide just

 punishment, and deter her from committing similar conduct in the future.

                                    CONCLUSION

       For the foregoing reasons, the United States respectfully requests that the

 Court sentence the defendant to a term of imprisonment of 51 months.

                                         Respectfully submitted,

                                         GREGORY W. KEHOE
                                         United States Attorney

                                         /s/ Diane S. Hu
                                         Diane S. Hu
                                         Assistant United States Attorney
                                         United States Attorney No. 220
                                         400 W. Washington Street, Suite 3100
                                         Orlando, Florida 32801
                                         (407) 648-7500
                                         diane.hu@usdoj.gov



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