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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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Cite this document

“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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