United States v. $1,707,197.13 From Fidelity Investment Bank Funds Account Number 6516

I. BACKGROUND

On August 6, 2021, the Government filed a Verified Complaint for Forfeiture against the defendant funds. Compl., Dkt. No. 1. The Government alleges that W. Nicoloff submitted loan applications for Bentley, Coastridge, David, Stonecreek, M. Nicoloff, and W. Nicoloff. Id. ¶ 9. The loan applications included altered documentation and other false information to obtain loans guaranteed by the SBA through the Paycheck Protection Program (“PPP”), a program created by the Coronavirus Aid, Relief, and Economic Security Act (“CARES Act”). Id. ¶ 10. W. Nicoloff obtained over $1.5 million in PPP loans from lenders. Id. ¶ 11. Instead of using loan proceeds for their intended

CENTRAL DISTRICT OF CALIFORNIA

CIVIL MINUTES - GENERAL

Case No. 8:21-cv-01310-JVS-ADS Date December 2, 2021 Title United States of America v. $1,707,197.13 from Fidelity Investment Bank Funds Account Number ‘6516, et al. trading activity unrelated to the businesses for which the loans were obtained. Id. ¶ 12. On loan applications submitted for Bentley, David, Stonecreek, and Coastridge, W. Nicoloff made numerous false statements involving the number of employees and the businesses’…