Superseding Information, United States v. Anatoly Rybin (Southern District of Georgia, May 2, 2022)
Summary
A superseding information filed May 2, 2022 in United States of America v. Anatoly Rybin, No. 4:22-CR-056 (Case 4:22-cr-00056-RSB-CLR), in the U.S. District Court for the Southern District of Georgia, Savannah Division, as Document 17. Its single count charges a false statement under 18 U.S.C. § 1001(a) made on or about December 23, 2020 in Bryan County. The information states that an EIDL application submitted to the U.S. Small Business Administration listed the cost of goods sold for the 12 months prior to the disaster as zero dollars and certified that all proceeds would be used as working capital. It states that the cost of goods sold figure was false, that not all proceeds were used for working capital, and that the SBA deposited money in reliance on the statements. The signature block names United States Attorney David H. Estes and Assistant United States Attorney Chris Howard.
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“Superseding Information, United States v. Anatoly Rybin (Southern District of Georgia, May 2, 2022).”
Original at ecf.gasd.uscourts.gov. Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/superseding-information-usa-v-rybin-dkt-17-f7f6789204/
, SHA-256 c4e8462ceff1331cce0c5bbec382543706915c428a9d3a14a49765c48bcf5313.Full text
Case 4:22-cr-00056-RSB-CLR Document 17 Filed 05/02/22 Page 1 of 3
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF GEORGIA
SAVANNAH DIVISION
UNITED STATES OF AMERICA ) SUPERSEDING INFORMATION
) 4:22-CR-056
v. )
) 18 U.S.C. § 1001(a)
ANATOLY RYBIN ) False Statements
THE UNITED STATES ATTORNEY CHARGES THAT:
COUNT ONE
False Statements
18 U.S.C. § 1001(a)
1. On or about December 23, 2020, in Bryan County, within the Southern
District of Georgia,
ANATOLY RYBIN,
did knowingly and willfully make a material false statement and representation in a
matter within the jurisdiction of the executive branch of the Government of the
United States, by submitting a loan modification application to the U.S. Small
Business Administration (SBA) that he knew contained false information.
2. More specifically, Defendant filled out an electronic Economic Injury
Disaster Loan (EIDL) application ending in 3972 with the SBA that included false
statements, including that the cost of goods sold for the 12 months prior to the
disaster totaled $0, and Defendant certified that he would use all proceeds of the
EIDL solely as working capital to alleviate economic injury caused by disaster
occurring in the month of January 31, 2020, and continuing thereafter. As Defendant
knew, his representation regarding the cost of goods sold was false, and he
Case 4:22-cr-00056-RSB-CLR Document 17 Filed 05/02/22 Page 2 of 3
subsequently did not use all proceeds of the EIDL for working capital. The statements
made on EIDL Application 3972 were material to the SBA. In reliance on the false
statements made by Defendant, the SBA deposited money into Defendant’s bank
account.
All in violation of Title 18, United States Code, Section 1001(a)(2).
2
Case 4:22-cr-00056-RSB-CLR Document 17 Filed 05/02/22 Page 3 of 3
David H. Estes
United States Attorney Assistant United States Attorney
*Lead Counsel
Patricia G. Rhodes
Assistant United States Attorney
Chief, Criminal Division
3
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