Case 3:14-cr-00012-JRS Document 1 Filed 01/21/14 Page 40 of 43 PageID# 40
Count Thirteen
(False Statement)
120.
The allegations set forth in paragraphs 1 through 107 are repeated and realleged
as if set forth fully herein.
121.
On or about February 1, 2013, within the Eastern District of Virginia and
elsewhere, defendants ROBERT F. MCDONNELL and MAUREEN G. MCDONNELL
knowingly madea false statement and report for the purpose of influencing the action of PenFed, a federal credit union, upon an application, commitment, and loan, and any change and extension
of any of the same, by renewal, deferment of action, and otherwise, in that on thejoint Uniform Residential Loan Application submitted to PenFed, the defendants listed total liabilities of $2,837,226 and listed no loans from or liabilities to JW, when in truth and in fact, as the defendants well knew, the defendants had received at least $120,000 in loans from JW that were
not reflected on theirjoint Uniform Residential Loan Application and were not included in the total liabilities listed.
(All in violation of Title 18, United States Code, Sections 1014 and 2.)
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