Court filing
Exhibit 1 — USA v. Sary - Ahmed M Sary (Dkt. 118.1)
Filed September 19, 2025 in USA v. Sary - Ahmed M Sary; one of 75 filings from this case.
Record facts
| Court | U.S. District Court for the District of Maryland |
|---|---|
| Filed | 2025-09-19 |
U.S. District Court for the District of Maryland · No. 1:23-cr-00344-RDB · Doc. 118-1 · 2025-09-19 · Docket on CourtListener
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Amanda L. Longmore, RPR, FCRR, Federal Official Court Reporter
1
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF MARYLAND
NORTHERN DIVISION
UNITED STATES OF AMERICA, )
)
vs.
)
CRIMINAL CASE NO.
)
1:23-cr-00344-RDB
AHMED SARY,
)
Defendant.
)
_________________________ )
WEDNESDAY, OCTOBER 18, 2023
Courtroom 5D
Baltimore, Maryland
TRANSCRIPT OF PROCEEDINGS
GUILTY PLEA
BEFORE THE HONORABLE RICHARD D. BENNETT
For the Government:
Paul Riley, Esquire
US Attorney's Office
36 South Charles Street, 4th Floor
Baltimore, MD 21201
For the Defendant:
Julie M. Reamy, Esquire
Julie M. Reamy, Attorney at Law, LLC
1 Olympic Place, Suite 900
Towson, MD 21204
Also Present:
Daniel Parker, FBI Special Agent
_______________________________________________________
(Computer-aided Transcription of Stenotype Notes)
Reported by: Amanda L. Longmore, RPR, CRR, FCRR
Federal Official Court Reporter
101 W. Lombard Street, 4th Floor
Baltimore, Maryland 21201
410-962-4474
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P R O C E E D I N G S
(2:36 p.m.)
THE COURT: This is calling the case of United States
versus Ahmed Sary, Criminal Number RDB-23-0344. I would note
that there was originally a complaint filed as to this
defendant quite some time ago, and now within the last -- I
guess last two or three weeks a Criminal Information was filed
and we are here for an arraignment and initial appearance on
the Criminal Information.
The masking policies of this court have previously
required that masks be worn in all public areas of the
courthouse. That is no longer the case, but it is still within
the discretion of the presiding judge. My courtroom has been
retrofitted with Plexiglass for quite some time and we started
taking down some of the Plexiglass, but we still have certain
portions of the courtroom that still are protected by
Plexiglass and we're gradually trying to get back to normal.
But I do inquire of the vaccination status of counsel and the
parties before me.
So with that, if counsel will identify themselves for the
record, please.
MR. RILEY: Good afternoon, Your Honor. Assistant
U.S. Attorney Paul Riley on behalf of the Government. With me
at counsel table is Special Agent Dan Parker of the FBI. We
are both vaccinated and boosted, Your Honor.
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THE COURT: Yes, Mr. Riley, nice to see you, and
Agent Parker, nice to see you here. I think you've been before
me before, I think.
MR. PARKER: Yes. Thank you, sir.
THE COURT: It's nice to have you back. Nice to see
you. You may be seated.
And on behalf of the defendant?
MS. REAMY: Good afternoon, Your Honor. For the
record my name is Julie Reamy. I represent Ahmed Sary who is
present and to my right.
THE COURT: Yes, Ms. Reamy. And you're privately
retained in this matter; is that correct?
MS. REAMY: I am. And also, Your Honor, I am
vaccinated and boosted twice.
THE COURT: Yes, and you're fully vaccinated and
boosted. And I know you're here as one of the select members
of our Criminal Justice Act panel, so it's nice to have you
here and I understand you're privately retained.
And good afternoon to you, Mr. Sary. Am I pronouncing
your name correctly, sir?
THE DEFENDANT: Ahmed Sary, yes.
THE COURT: Mr. Sary, have you been fully vaccinated?
THE DEFENDANT: Yes, but no boost.
THE COURT: All right. But you have been vaccinated?
THE DEFENDANT: I did.
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THE COURT: Okay, that's fine. Thank you very much.
Ms. Reamy, do you know who the U.S. Probation Officer is
who will be assigned in this case?
MS. REAMY: Yes. It's going to be Jessica Jackson.
We're scheduled to meet with her after the hearing.
THE COURT: All right. Hold on one second here,
please. Jessica Jackson?
MS. REAMY: Yes.
THE COURT: Mr. Sary, let me just go over the process
here in federal court today on this matter.
You have been charged by way of a Criminal Information by
the U.S. Attorney for the District of Maryland. Ordinarily,
the Government cannot just of its own charge someone with a
crime. There has to be a determination of probable cause. And
normally it's before a grand jury and it consists of
approximately 23 citizens from the community and they determine
if there's probable cause to believe that you committed a
particular offense or there may be a preliminary hearing in
front of a judge to determine whether or not there is probable
cause to believe you committed an offense.
Here, there is -- you're proceeding by way of a Criminal
Information, and I have before me a waiver of indictment form
here in this matter that indicates that you understand that you
have a right to prosecution by indictment and you're consenting
to prosecution by Criminal Information; is that correct?
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THE DEFENDANT: Yes.
THE COURT: I'm sorry, you have to keep your voice
up, please.
THE DEFENDANT: Yes.
THE COURT: Okay. And you've discussed the fact that
you've been accused of an offense that the punishment for which
may be imprisonment for more than one year and you understand
your rights to require that you be indicted by a grand jury; is
that correct?
THE DEFENDANT: Yes, Your Honor.
THE COURT: All right. And are you under the
influence of any drugs or alcoholic beverage or any medication
of any kind?
THE DEFENDANT: No.
THE COURT: And you have -- you're satisfied you've
discussed this matter with your attorney Ms. Reamy in terms of
your rights in this regard?
THE DEFENDANT: Yes.
THE COURT: All right. I find it's a knowing and
intelligent waiver for reasons so indicated here and as well as
the reasons that we'll be dealing with during the guilty plea
in this matter.
Ms. Maldeis, the waiver of indictment form will be filed.
Let me just go over -- essentially there is an initial
appearance here under Rule 5 of the Federal Rules of Criminal
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Procedure with respect to this matter and this is your initial
appearance here.
The charge against you -- Ms. Reamy, I gather that he
waives reading of the entire Criminal Information; is that
right?
MS. REAMY: Yes, Your Honor.
THE COURT: But the charge basically here is that you
committed wire fraud conspiracy in violation of 18 United
States Code § 1349, and specifically it's alleged that you ran
a purported financial services business called Amex Financial
Group and that you prepared false and fraudulent Paycheck
Protection Program loan applications. I gather that was in
conjunction with the steps during the pandemic; is that
correct, Mr. Riley?
MR. RILEY: Correct, Your Honor.
THE COURT: And that program was implemented during
the throes of the COVID-19 pandemic, and it's alleged that you
prepared false and fraudulent loan applications for various
borrowers and false and fraudulent Economic Injury Disaster
Loan applications so as to wrongfully procure funds from that
program. Do you understand that?
THE DEFENDANT: I understand that.
THE COURT: And it's alleged that one of the victims,
if not the main victim, was Cross River Bank, a federally
insured financial institution headquartered in New Jersey,
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which was approved by the Small Business Administration to be a
lender and participated as a lender in the Paycheck Protection
Program, the PPP program during the pandemic.
And that program was essentially a Coronavirus relief
program, but in order to obtain such loans, qualifying
businesses had to submit loan applications and under the
Coronavirus Aid Relief and Economic Security Act, known as the
CARES Act, the Small Business Administration was authorized to
provide funds, essentially, with respect to this program and
that you were -- essentially that included an Economic Injury
Disaster Loan program application.
And it is essentially alleged that beginning in or around
April of 2020 and continuing through in or around January of
2022, here in the District of Maryland, that you knowingly and
willfully conspired with others to willfully execute and
attempt to execute a scheme and artifice to defraud the Small
Business Administration, Cross River Bank, and other lenders
and to obtain money by allegedly false and pretenses.
Do you understand the general nature of the charges
against you?
THE DEFENDANT: Yes.
THE COURT: And the manner and means of the scheme to
defraud included essentially both wire transfers and perhaps
even paper transfers, and it also involved filing false and
fraudulent records, including false United States Internal
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Revenue Service forms and tax records.
Again, do you understand the nature of those allegations?
THE DEFENDANT: Yes.
THE COURT: I think that fairly summarizes the nature
of the charges against you. You have a right to employ counsel
or request appointment of counsel. The reason I inquired of
Ms. Reamy's status is she's well known to the Court and is a
highly respected lawyer here in our court and she also appears
here many times as court-appointed counsel. But in this matter
she's indicated that she was previously retained. You have a
right to employ counsel. If you were unable to employ counsel,
you could have then sought to have the appointment of
court-appointed counsel. Do you understand that?
THE DEFENDANT: Could we just stop?
THE COURT: I'm sorry?
(Pause in Proceedings.)
THE COURT: Do you understand if you could not have
afforded to retain --
THE DEFENDANT: Yes.
THE COURT: -- Ms. Reamy, you could have applied for
court-appointed counsel. You would have to show financial
indigency and an inability to pay. Not just anyone gets
court-appointed counsel, but you would have that right if you
were unable to employ counsel.
You have a right to a preliminary hearing, as I've
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indicated, and you're not required to make any statement. In
any statement that you make, you may stop at any time under
principles of* the Supreme Court set forth under the --
holdings of the Supreme Court as set forth in the case of
Miranda versus Arizona in 1966, and any statement you do make
may be used against you. Do you understand that?
THE DEFENDANT: I understand.
THE COURT: You understand all your rights in that
regard?
THE DEFENDANT: Yes.
THE COURT: All right. And we're ready to proceed by
way of the arraignment here. That's the initial appearance,
but we're about to proceed by way of an arraignment here.
I would note that I have reviewed the plea agreement in
this case which will be introduced as Government Exhibit Number
1 in a few moments here. And specifically, in Paragraph 10,
there is an agreement that you have reached with the Government
with respect to this matter. And the guilty plea that you're
about to proffer here this afternoon is pursuant to an
agreement with the Government as set forth in the plea
agreement letter, which will be introduced as Government
Exhibit 1 shortly, as I've said. And in Paragraph 10 it notes
that you're pleading guilty here pursuant to a specific rule of
the Federal Rules of Criminal Procedure which provides that a
criminal defendant may agree upon a specific sentence or a
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range of sentence. Under 11(c)(1)(C) of the Federal Rules of
Criminal Procedure, you may agree upon a range of sentence or a
specific sentence.
Here, you've agreed with the Government that the
appropriate sentence in this case would be anywhere from 60 to
114 months' incarceration in federal prison, which is anywhere
from five years to nine and a half years in prison. Do you
understand that?
THE DEFENDANT: Yes.
THE COURT: I will certainly accept your guilty plea
here today under the terms of that agreement. That means if I
were inclined to sentence you to one day more than 114 months'
imprisonment, one day more than nine and a half years in
prison, you'd be free to withdraw your plea of guilty. Do you
understand that?
THE DEFENDANT: Yes.
THE COURT: By the same token, if I were inclined to
sentence you to one day less than 60 months' incarceration, one
day less than five years imprisonment, the Government could
withdraw from the plea agreement. Do you understand that?
THE DEFENDANT: Yes.
THE COURT: So I will certainly accept your guilty
plea under those terms. And consistent with that, Paragraph 11
as we'll be discussing, notes that you waive -- both you and
the Government waive appeal of any sentence within that range.
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It will be up to your -- the lawyers will argue where you
should be sentenced within that range and I'll be reviewing a
Presentence Investigation Report which will be prepared by
Ms. Jackson, the U.S. Probation Officer with whom you'll be
meeting after these proceedings. Do you understand that, sir?
THE DEFENDANT: Yes.
THE COURT: And so with that, Mr. Riley, I also to
note there has been a notice to victims here, both the
Government victims as well as officials of Cross River Bank,
correct?
MR. RILEY: Yes, Your Honor.
THE COURT: So with that I think that we're ready to
proceed with the guilty plea to the Criminal Information in
this case. And, Ms. Maldeis, if you would administer the oath
to the defendant.
(Ahmed Sary was duly sworn.)
THE CLERK: And sir, can you please state and spell
your first and last name for the record, please?
THE DEFENDANT: Ahmed, A-h-m-e-d, Sary, S-a-r-y.
THE CLERK: Thank you. And sir, what is your age?
THE DEFENDANT: 46.
THE CLERK: What is the year -- just the year -- of
your birth?
THE DEFENDANT: 1978.
THE CLERK: Have you received a copy of the
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Information provided to you by the Government?
THE DEFENDANT: I'm sorry, say again.
THE CLERK: Have you received a copy of the
Information?
THE DEFENDANT: Yes. Yes.
THE CLERK: Have you read the Information or has the
substance of the charge been explained to you?
THE DEFENDANT: Yes.
THE CLERK: Do you understand the charge placed
against you?
THE DEFENDANT: Yes.
THE CLERK: Ms. Reamy, you represent the defendant.
Are you satisfied that he understands the charge?
MS. REAMY: Yes.
THE CLERK: Mr. Sary, how do you wish to plead as to
Count 1 of the Information?
THE DEFENDANT: Guilty.
THE CLERK: The plea is guilty as to Count 1 of the
Information; is that correct?
THE DEFENDANT: Yes.
THE COURT: Thank you, Ms. Maldeis.
I would note that at the time of sentencing here, when you
return here to this court for sentencing in -- I think it's
going to be set for February 1st of next year, Mr. Sary, that
the Government will dismiss the initial complaint that was
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filed.
Correct, Mr. Riley?
MR. RILEY: Yes, Your Honor.
THE COURT: There are no other counts to be
dismissed, correct?
MR. RILEY: Correct, Your Honor.
THE COURT: All right. So with that, Mr. Sary -- and
again, Ms. Reamy, am I pronouncing his name correctly, Sary?
MS. REAMY: Yes.
THE COURT: Mr. Sary, do you understand, sir, that
you're now under oath?
THE DEFENDANT: Yes.
THE COURT: And do you understand if you were to
answer any of my questions falsely, those answers could later
be used against you in another prosecution for perjury or for
making false statements?
THE DEFENDANT: Yes.
THE COURT: So it's very important you answer my
questions truthfully. If you don't understand a question,
we'll stop, we're not in any hurry here, and you can talk to
your attorney Ms. Reamy.
How far did you get in school, sir?
THE DEFENDANT: How far?
THE COURT: How far did you get in school, yes.
THE DEFENDANT: High school.
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THE COURT: High school. You are a high school
graduate?
THE DEFENDANT: Yes.
THE COURT: And you obviously, then, can read and
write the English language?
THE DEFENDANT: Yes.
THE COURT: Have you been treated recently for any
mental illness or addiction to narcotic drugs of any kind?
THE DEFENDANT: No.
THE COURT: Are you currently under the influence of
any drugs or medication or any alcoholic beverage of any kind?
THE DEFENDANT: No.
THE COURT: Is there medication that you normally
take which you did not take today?
THE DEFENDANT: No.
THE COURT: Do you take any kind of regular
medication?
THE DEFENDANT: Just acid reflux.
THE COURT: For acid reflux?
THE DEFENDANT: Yes, I do.
THE COURT: All right. Ms. Reamy, are you satisfied
that your client is competent to proceed with this guilty plea
here today?
MS. REAMY: Yes, Your Honor.
THE COURT: Have you received a copy of the one-count
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Criminal Information in this case, Mr. Sary, that is the
written charges made against you?
THE DEFENDANT: I'm sorry?
THE COURT: Have you received a copy of the Criminal
Information in this case, that is the written charges made
against you?
THE DEFENDANT: Yes.
THE COURT: And have you fully discussed these
charges with your attorney Ms. Reamy?
THE DEFENDANT: Yes.
THE COURT: Have you discussed the whole situation
with her including the evidence in the case?
THE DEFENDANT: Yes.
THE COURT: Witnesses that would be called and
perhaps the possibility of a trial and even an appeal if you
were found guilty by a jury in this case?
THE DEFENDANT: Yes.
THE COURT: Are you fully satisfied with Ms. Reamy
and her representation and the advice which she's given you?
THE DEFENDANT: Yes.
THE COURT: Is there anything you asked her to do
which she has not done?
THE DEFENDANT: No.
THE COURT: The Court has been advised that there is
a plea agreement in this case as set forth in a letter of
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September 14, 2023, from Assistant U.S. Attorney Paul Riley to
your attorney Julie Reamy, which has been marked as Government
Exhibit 1, along with any attachments thereto.
Ms. Reamy, if you'll retrieve that from Ms. Maldeis here
up at the clerk's desk, and Ms. Maldeis will walk down and give
the original of that letter to you.
Looking there, Mr. Sary, at the original plea agreement
letter as well as any attachments thereto, is that your
signature there, sir, on Page 10 of the plea agreement letter?
THE DEFENDANT: Yes.
THE COURT: And as to any attachments, is that your
signature there on Page 16 as well?
THE DEFENDANT: Yes.
THE COURT: And did you have an opportunity to read
and discuss the plea agreement letter with your attorney,
Ms. Reamy, before you signed it in those places?
THE DEFENDANT: Yes.
THE COURT: And this is, in fact, the same agreement
which you signed; is that correct?
THE DEFENDANT: Correct, yes.
THE COURT: Has anyone made any other or different
promises or assurances to you in an effort to induce you to
plead guilty in this case other than what is set forth in the
plea agreement letter?
THE DEFENDANT: No.
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THE COURT: Are you satisfied, Ms. Reamy, that this
plea agreement letter sets forth the complete agreement that
your client has with the Government?
MS. REAMY: Yes, Your Honor.
THE COURT: And, Mr. Sary, are you satisfied that
this plea agreement letter sets forth the complete agreement
you have with the Government?
THE DEFENDANT: Yes.
THE COURT: All right. Ms. Reamy, if you'll return
that to Ms. Maldeis, and that will be introduced as Government
Exhibit 1 for purposes of these proceedings.
Does any portion need to be sealed from the point of view
of the Government, Mr. Riley?
MR. RILEY: No, Your Honor.
THE COURT: Ms. Reamy, from your point of view?
MS. REAMY: No, Your Honor.
THE COURT: All right. So that will not be sealed,
Ms. Maldeis, and can be filed as a matter of record.
Did you understand that -- I believe Ms. Reamy has a copy
of that plea agreement letter there at the table, Mr. Sary.
And in Paragraph 21 of the plea agreement letter, it notes that
the Court is not a party to it. I haven't signed it anywhere.
Do you understand that?
THE DEFENDANT: Yes.
THE COURT: So I'll certainly abide by it under Rule
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11(c)(1)(C) as I've indicated, and if I were not inclined to,
either side could withdraw from the plea agreement but the
11(c)(1)(c) plea sets a range of 60 to 114 months, but that is
an agreement between you and the Government which I will
accept, and if I don't, I'll certainly let everyone know, but
I'm not a party to the agreement. I haven't signed it
anywhere. Do you understand that?
THE DEFENDANT: Yes.
THE COURT: Has anyone tried to force you or threaten
you to plead guilty in this case?
THE DEFENDANT: No.
THE COURT: Are you pleading guilty on your own
freely and because you are, in fact, guilty of the crime
charged?
THE DEFENDANT: Yes.
THE COURT: Do you understand the offense to which
you're pleading guilty, specifically conspiracy to commit wire
fraud affecting a financial institution in violation of 18
United States Code § 1349 and 1343 is a felony offense? Do you
understand that?
THE DEFENDANT: Yes.
THE COURT: And if I accept your plea here this
afternoon and you're adjudged guilty of that offense, that
adjudication may result in your being deprived of certain
valuable civil rights. Do you understand that?
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THE DEFENDANT: Yes.
THE COURT: You may lose the right to vote, you may
lose the right to run for public office, you may lose the right
to have firearms or ammunition. Do you understand that?
THE DEFENDANT: Yes.
THE COURT: Is your client an American citizen,
Ms. Reamy?
MS. REAMY: Yes.
THE COURT: All right. So is he a naturalized
American citizen?
MS. REAMY: He's a naturalized citizen, Your Honor.
THE COURT: All right. So deportation is not an
issue here.
MS. REAMY: Correct.
THE COURT: All right. So to that extent, Mr. Sary,
fortunately for you, you've become an American citizen.
Otherwise you would face potential deportation issues. I'll
make a note here.
You might also be unable to keep certain licenses or
permits or jobs as a result of your guilty plea here or be able
to keep such benefits as public housing, for example, or
educational assistance loans, all those may be lost to you as a
result of your federal conviction here. Do you understand
that?
THE DEFENDANT: Yes.
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THE COURT: If you've been convicted of another crime
in the past and you were on parole or probation, you could face
the possibility of violation of parole or probation because of
your conviction here. Do you understand that, sir?
THE DEFENDANT: Yes.
THE COURT: And by the same token if you were
convicted of another crime in the future you might receive a
harsher sentence from another judge in another courtroom
because of your conviction here. Do you understand that?
THE DEFENDANT: Yes.
THE COURT: And furthermore, the plea agreement
provides, first of all, in Paragraphs 12 through 16 for certain
matters of forfeiture in terms of forfeiting certain assets, is
forfeiture a factor here, Mr. Riley?
MR. RILEY: Yes, Your Honor. In Paragraph 13, the
defendant has agreed to a money judgment in the amount of
$3,627,489.22 in U.S. currency.
THE COURT: All right. Thank you. I missed that
because I know Paragraph 20 has a restitution figure as well.
MR. RILEY: Yes, Your Honor.
THE COURT: But forfeiture is -- essentially they are
assets that have already been seized by the Government; is that
right?
MR. RILEY: No, Your Honor, but the Government is
asking the Court to -- the defendant has agreed to a money
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judgment in that amount.
THE COURT: All right. You understand that
essentially Paragraphs 12 through 16 in terms of forfeiture
establish your agreement to have a money judgment against you
in the amount of $3,627,489.22. Do you understand that?
THE DEFENDANT: Yes.
THE COURT: And that would presumably be secured by
some type of financial accounts or money that's available at
this point in time. Is that right, Mr. Riley?
MR. RILEY: It's not at this time, Your Honor, but
down the road --
THE COURT: Okay.
MR. RILEY: -- our office's Asset Recovery Unit will
take the appropriate steps.
THE COURT: Now, as to that, that $3,627,489.22
judgment, that is separate from any kind of joint and several
liability or it would go towards joint and several liability?
MR. RILEY: That is separate from joint and several
liability.
THE COURT: Correct, Ms. Reamy?
MS. REAMY: Yes.
THE COURT: That means also in Paragraph 20 of the
plea agreement -- I'll make a note -- there's also reference to
potential restitution of some $17.9 million. That will be
joint and several liability with any of the other defendants
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who were involved in this overall conspiracy. Do you
understand that?
THE DEFENDANT: Yes.
THE COURT: That means if one person has all the
money, the Government could get all the money from that one
person, or it means that different people might have to make
contributions. Do you understand that?
THE DEFENDANT: Yes.
THE COURT: As was noted in Paragraph 3 of the plea
agreement, do you understand that the maximum sentence provided
by statute for this offense is 30 years imprisonment, five
years of supervised release, and a maximum fine of $1 million
or twice the gain or loss anticipated. They are the maximum
penalties that obviously your 11(c)(1)(C) plea would protect
you from any kind of imprisonment for 30 years. Do you
understand that?
THE DEFENDANT: Yes.
THE COURT: And you must pay a special assessment of
$100 at the time of sentencing when you return here for
sentencing. Do you understand that?
THE DEFENDANT: Yes.
THE COURT: And I've already mentioned the Court may
also order restitution, and Paragraph 20 notes a restitution
figure that would be joint and several with other defendants of
some $17.9 million. Do you understand that?
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THE DEFENDANT: Yes.
THE COURT: Now, I mentioned supervised release,
Mr. Sary. Supervised release involves your compliance with
certain conditions set by the Court and monitored by the
Probation Office after your prison sentence.
Do you understand that if you were to violate conditions
of supervised release after you return from prison you could be
sent back to federal prison without any credit for the time
already served. Do you understand that?
THE DEFENDANT: Yes.
THE COURT: It'd be a totally separate matter.
You'll be on supervised release for a period of time after you
finish your prison sentence. And that's meant to be a
constructive process. It's not a game of trying to catch you
doing something wrong, but it's meant to help supervise you, as
it says, in your release to acclimate yourself back to civilian
life. Do you understand that?
THE DEFENDANT: Yes.
THE COURT: And if you were to violate those
conditions of supervised release, you could perhaps be sent
back to prison without any credit for the time already served.
Do you understand that?
THE DEFENDANT: Yes, Your Honor.
THE COURT: Are you satisfied then, Ms. Reamy, that
Mr. Sary understands all the possible consequences of his plea
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of guilty?
MS. REAMY: Yes, Your Honor.
THE COURT: And, Mr. Sary, are you satisfied that you
understand all the possible consequences of your plea of
guilty?
THE DEFENDANT: Yes.
THE COURT: Let me just go over the process here in
federal court with respect to sentencing. This is a little
distinct from state court criminal cases.
There are two key opinions of the United States Supreme
Court that outline the process for sentencing in federal court.
First of all, in a case of United States versus Booker decided
now almost 19 years ago in January of 2005, the United States
Supreme Court upheld the constitutionality of the Federal
Sentencing Guidelines in the case of United States versus
Booker. But the Supreme Court upheld the constitutionality of
the guidelines with the deletion of two particular sections of
the guidelines which had previously rendered the guidelines
mandatory.
The Supreme Court specifically noted in the Booker case
with the deletion of any mandatory provisions the balance of
the Federal Sentencing Guidelines was constitutional but from
that point forward in January of 2005, the Federal Sentencing
Guidelines were to be applied in an advisory context, meaning
that they were not binding upon federal judges but federal
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judges should still take them into account and they were
rendered effectively advisory as a result of that opinion. Do
you understand that?
THE DEFENDANT: Yes.
THE COURT: And about three years later in a case of
Gall versus the United States, the Supreme Court specifically
provided further instruction to federal judges noting that
federal judges should not presume that the federal sentencing
guideline range is reasonable but it is a starting point in a
multistep process, pursuant to which first there's a
calculation of the guidelines and then there's the
consideration of other factors apart from the guidelines, the
goal being to impose a sentence which is sufficient but not
greater than necessary to achieve the goals of sentencing. And
there are other factors to be considered as well under 18
United States Code § 3553, which is referenced in Paragraph 5
of your plea agreement letter.
Those other factors to consider include your personal
history and characteristics, the nature and circumstances of
the offense, the sentence to be imposed or either have been
imposed or would be imposed upon similarly situated
individuals. All those factors are taken into account when the
Court imposes the sentence when you return here on February
1st.
Do you understand that, sir?
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THE DEFENDANT: Yes.
THE COURT: And in fact, in Paragraph 5 of the plea
agreement letter, which I've mentioned, the guidelines are
discussed. I gather you've discussed the guidelines that apply
here in this case; is that right?
THE DEFENDANT: Yes.
THE COURT: And Paragraph 6 outlines the guideline
calculation here, essentially in terms of a base offense level
of seven, there's a 20-level increase because of the loss
amount here. There is a two-level increase because of the
offense involving more than ten victims. There is a two-level
increase because of gross receipts from a financial
institution. There's another two-level increase because of the
use of sophisticated means. There's a three-level increase
because you were a manager or supervisor, although not an
organizer or a leader.
There will be a total of three levels of a downward
adjustment for your acceptance of responsibility, but it's
anticipated that the total offense level here under the
advisory guidelines here will be 33. Do you understand that?
THE DEFENDANT: Yes.
THE COURT: And that would definitely expose you to
time in federal prison. Do you understand that?
THE DEFENDANT: Yes.
THE COURT: Paragraph 7 indicates there's no
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agreement as to your criminal history, which would be
important. If you have an extensive criminal history that will
be a factor in my ultimately approving the agreed sentence of
some six years to nine and a half years incarceration. Do you
understand that, sir?
THE DEFENDANT: Yes.
THE COURT: And as I've already noted -- well,
Paragraph 8, first of all, also notes that there are no other
guideline issues involved here, and Paragraph 9 notes that the
Government will recommend a reasonable sentence within the
five- to nine-and-a-half-year range. That will be up to the
Government what it recommends, and obviously Ms. Reamy can
recommend a sentence at that low end of that agreed range of
five years. Do you understand that process, sir?
THE DEFENDANT: Yes.
THE COURT: And Paragraph 10, as I've already noted,
provides for the agreed range of some five years to nine and a
half years' incarceration.
And do you also understand that as a result of your
conviction here, Mr. Sary, that you will not be permitted to
own, possess, or use a firearm. Do you understand that?
THE DEFENDANT: Yes.
THE COURT: Now, do you understand I'll not be able
to determine the advisory guideline range in this case until
after a Presentence Investigation Report has been prepared by
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the U.S. Probation Officer, in this case, it will be Jessica
Jackson, and after she has prepared that report and after both
you and Government counsel and your attorney have had an
opportunity to review it and note any objections to it.
THE DEFENDANT: Yes.
THE COURT: You'll meet with her later today, she'll
prepare a report, she'll see that Mr. Riley gets a copy, she'll
see that Ms. Reamy gets a copy. Ms. Reamy will go over it with
you. Either side will note any objections to it. Then
Ms. Jackson either will or will not make changes to the
presentence report and then ultimately it will come to me. Do
you understand that general process?
THE DEFENDANT: Yes.
THE COURT: So I'm the last one of all of you to see
it. Do you understand that?
THE DEFENDANT: Yes, Your Honor.
THE COURT: So do you understand that the sentence
imposed within that five- to nine-and-a-half-year range might
be different from any estimate which Ms. Reamy's given you? Do
you understand that?
THE DEFENDANT: Yes.
THE COURT: She cannot predict exactly where on that
five- to nine-and-a-half-year range I'm going to sentence you
because I don't know until I have an opportunity to review the
presentence report. Do you understand that?
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THE DEFENDANT: Yes.
THE COURT: Do you also understand, Mr. Sary, that
parole has been abolished in the federal system and it's not
the same as the state system?
THE DEFENDANT: Yes.
THE COURT: Let me explain what that means.
For example, let's say it's a six-year sentence within the
agreed range. Under state law, a six-year sentence you might
serve one-third of your time and serve maybe two years and then
be on parole for the next four years under the auspices of a
parole board. That's not the way the federal system works.
There is no parole in the federal system.
Essentially, you can get between 50 and 54 days a year of
good time credit, which means in the case of the example of a
six-year sentence, you might accumulate good time credit of
some six months over a period of five years and then you could
be released early from the Bureau of Prisons, but it's not a
system where you just serve one-third of the sentence. Do you
understand that?
THE DEFENDANT: Yes.
THE COURT: And in Paragraph 11 of the plea
agreement, as I think I've specifically already addressed, both
you and the Government waive appeal of any sentence within that
range. Do you understand that?
THE DEFENDANT: Yes.
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THE COURT: And Paragraph 11(c) actually also
reflects that you waive rights under what is known as the
Freedom of Information Act. That is a law that was passed by
the U.S. Congress that permits American citizens to seek
information from certain government agencies. You've had
access to discovery in this case through your attorney and now
that you're pleading guilty, you have no further right to file
a Freedom of Information Act request with the Department of
Justice. Do you understand that, sir?
THE DEFENDANT: Yes.
THE COURT: I also want to make sure you understand
your waiver of certain rights under Paragraph 4 of the plea
agreement letter. Specifically, do you understand that you
waive all rights in connection with a jury trial in this case?
THE DEFENDANT: Yes.
THE COURT: Do you understand you have a right to
plead not guilty to these charges and persist in that plea and
you have a right to a trial by jury for which 12 people would
be selected as jurors?
THE DEFENDANT: Yes.
THE COURT: And do you understand you'd have a right
to participate with Ms. Reamy in the selection of a jury in
this case?
THE DEFENDANT: Yes.
THE COURT: All the jurors would be brought into the
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courtroom and you'd be able to see them and see what they look
like and watch their responses and you'd be able to have input
with Ms. Reamy in terms of the selection of a jury in this
case. Do you understand that?
THE DEFENDANT: Yes.
THE COURT: Do you also understand that at trial
you'd be presumed to be innocent and the Government would have
to prove your guilt beyond a reasonable doubt?
THE DEFENDANT: Yes.
THE COURT: And there would have to be a unanimous
verdict of all 12 jurors before you could be convicted on the
one-count Criminal Information in this case. Do you understand
that?
THE DEFENDANT: Yes.
THE COURT: If 11 jurors voted to convict you and one
voted to acquit there would be a mistrial and we'd have a new
trial. You could only be convicted on the unanimous verdict of
all 12 jurors. Do you understand that, Mr. Sary?
THE DEFENDANT: Yes, Your Honor.
THE COURT: And furthermore, do you understand you'd
have the right to the assistance of your counsel for your
defense and the right to see and hear all witnesses and to
cross-examine all witnesses?
THE DEFENDANT: Yes.
THE COURT: And do you also understand on your own
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part you would have the right to decline to testify unless you
voluntarily elected to testify in your own defense?
THE DEFENDANT: Yes.
THE COURT: Under the Fifth Amendment to our
Constitution you have a privilege against self-incrimination.
The Government could not compel you to be a witness in this
case, I could not compel you to be a witness, I could not call
you as a witness. Do you understand that?
THE DEFENDANT: Yes.
THE COURT: If you did choose to go to trial and
testify, however, you could be subject to impeachment on
cross-examination and could be cross-examined about any prior
criminal record that you have if you had one. Do you
understand that?
THE DEFENDANT: Yes.
THE COURT: Do you also understand that should you
decide not to testify or put on any evidence but still go to
trial, that the facts of your not testifying or putting on any
evidence could not be used against you?
THE DEFENDANT: Yes.
THE COURT: And not only could it not be used against
you, but as I instructed the jury as it began its
deliberations, I would specifically tell the jury that they
should not consider in any way that you did not testify or tell
them that the burden never shifts from the Government to a
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criminal defendant. The burden is always upon the Government
to prove guilt beyond a reasonable doubt. That burden never
shifts to a defendant. A criminal defendant is never required
to prove his innocence. The Government is always required to
prove guilt beyond a reasonable doubt. Do you understand your
rights in that regard, Mr. Sary?
THE DEFENDANT: Yes.
THE COURT: And furthermore, do you understand you
have the right to the issuance of subpoenas to compel the
attendance of witnesses to testify in your defense?
THE DEFENDANT: Yes.
THE COURT: Just as the Government can require people
to come into the courtroom, so can you. You can give the names
and addresses of any persons whom you wanted to call to
Ms. Reamy and she would file those subpoenas with the Clerk of
the Court and those subpoenas would be issued and Ms. Reamy
would see that those persons received subpoenas. So just as
the Government could compel people to come into the courtroom,
so can you. Do you understand that, sir?
THE DEFENDANT: Yes.
THE COURT: And if there was a trial in this case and
if you were found guilty, you could appeal both the verdict of
guilty as well as the sentence imposed. There'd be no waiver
of any right as there is now in terms of any kind of an appeal.
Do you understand that?
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THE DEFENDANT: Yes.
THE COURT: Do you further understand that by
entering this plea of guilty, if I accept that plea in a few
moments, there will be no trial and you will have waived or
given up all your other rights to trial as I've just described
them?
THE DEFENDANT: Yes.
THE COURT: Now, the charge to which you're pleading
guilty, one-count Criminal Information, is that on or about
from April 2020 to January of 2022, that you were engaged in a
conspiracy pursuant to which -- and these are elements the
Government would have to prove at trial beyond a reasonable
doubt. These are elements of proof of which the Government's
going to have to offer me in a few minutes here this afternoon,
that two or more persons agreed to try to accomplish a common
unlawful plan, that is alleged in the Criminal Information,
that two or more persons agreed to try to accomplish that
common plan to commit a fraud as involved in transmitting or
causing to be transmitted by means wire, radio, or television
communications in interstate and foreign commerce, it having
been -- that scheme having been devised or intending to devise
the scheme, that it affected a federally insured financial
institution, and that you knew the unlawful purpose of the
enterprise and willfully joined in it.
Do you understand the basic elements of the offense to
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which you're pleading guilty here today, Mr. Sary?
THE DEFENDANT: Yes, Your Honor.
THE COURT: So with that, you may be seated for a few
minutes and I'll call upon Assistant U.S. Attorney Paul Riley
to summarize and make a representation concerning the facts the
Government would be prepared to prove at trial so as to
establish an independent factual basis for this Court's
acceptance of a guilty plea to the one-count Criminal
Information in this case.
Mr. Riley, I'll be glad to hear from you.
MR. RILEY: Yes, Your Honor. Those facts are set out
in Pages 11 through 16 of Government Exhibit 1, the parties'
plea agreement, and I'll summarize them as follows:
The defendant Ahmed Sary, born March 1978, is a resident
of Baltimore, Maryland. Beginning in April 2020 and continuing
through January 2022 in the District of Maryland, the
defendant, his coconspirator H.D. and others conspired together
to engage in a scheme to defraud a financial institution, Cross
River Bank, and the United States Small Business
Administration, or SBA, and other SBA-approved lenders to
obtain numerous fraudulent Paycheck Protection Program, or PPP,
loans and Economic Injury Disaster Loans, or EIDLs.
For the purpose of executing and attempting to execute
this scheme, the defendant and his coconspirators knowingly and
willfully transmitted and caused to be transmitted by means of
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wire communications in interstate and foreign commerce
writings, signs, signals, pictures, and sounds in violation of
18 U.S.C. §§ 1349 and 1343.
The defendant prepared numerous false and fraudulent EIDL
and PPP loan applications for purported businesses that did not
exist in any legitimate capacity and that included false
information concerning, among other things, number of
employees, monthly payroll costs, and revenue.
The PPP applications routinely included false and
fraudulent Internal Revenue Service, IRS, tax forms created by
H.D. and that were provided to defendant along with fabricated
bank statements prepared by the defendant. These forms were
submitted by defendant and his coconspirators with the PPP
applications to substantiate the false representations made in
the applications.
The defendant received kickback payments from the loan
borrowers in exchange for his assistance in connection with the
submission of the fraudulent PPP and EIDL applications,
ultimately receiving $2,714,217.22 in kickbacks as a result of
the scheme to defraud charged in Count 1 in the Information.
These kickbacks amounted to at times up to 30 percent of
the amount of the loan in the application. The defendant used
the fraudulently obtained funds to travel to Dubai and Egypt on
multiple occasions, stay at luxury hotels including the Four
Seasons while there, to purchase property in Egypt and to,
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among other things, open a beachfront restaurant in Alexandria,
Egypt called Sary's Kitchen.
The conspiracy resulted in the disbursement of at least
$14,807,609.37 in fraudulently obtained PPP funds in connection
with more than 85 fraudulent PPP loans. More than ten
financial institutions were victims in connection with the
scheme, and the defendant derived more than $1 million in gross
receipts from one or more financial institutions as a result of
his offense.
The conspiracy likewise resulted in the disbursement of
$3,093,670.50 in EIDL funds in connection with 57 EIDL
applications.
In addition to loan fee kickbacks, the defendant himself
received $959,559.00 in PPP/EIDL funds for various purported
businesses that he controlled, and the defendant's crimes are
discussed in further detail in the Stipulation of Facts.
Now, with respect to the fraudulent applications for
businesses associated with the defendant in connection with the
conspiracy and scheme to defraud, the defendant submitted
multiple false and fraudulent EIDL and PPP loan applications in
connection with various purported businesses for which he owned
or otherwise had an interest.
There was a purported financial services business, AMEX
Financial Group, a purported meat packing business, Am Halal
Meat, a purported clothing company, Exclusive Menswear,
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purported talent agency, Sary Stars. None of these businesses,
in fact, existed in any legitimate capacity.
The submission of these applications resulted in multiple
interstate wires from Maryland to Virginia which was the
location of the SBA servers. There's a chart in the
Stipulation of Facts which lists entity, the loan type, the
loan amount, as well as the funded date for multiple PPP and
EIDL loans. The total amount is $913,272 as reflected in the
chart.
In the next section there is a discussion of -- and this
is on Page 13 -- the defendant's loan kickback scheme. In
addition to obtaining the fraudulent PPP and EIDL funds for his
own purported businesses, the defendant engaged in a scheme
with coconspirator H.D. to assist other coconspirators with
obtaining EIDL and PPP loans for various purported businesses
that did not exist in any legitimate capacity in exchange for a
kickback payment. Mr. Sary would receive a kickback, typically
20 to 30 percent of the fraudulent loan amount in exchange for
his services, and at times would give H.D. a small portion of
that fee, typically 2 percent to 5 percent of the fraudulent
amount if H.D. assisted with the fraudulent application.
These applications grossly inflated the numbers of
employees, grossly inflated monthly payroll costs of the
purported businesses. The PPP applications contained various
false and fraudulent IRS records prepared by H.D. and provided
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to defendant to support the payroll figures included in the
fraudulent PPP applications, including false U.S. IRS Forms
940, 941, and 944 for the purported businesses.
The PPP applications likewise contained false and
fraudulent February of 2020 bank statements prepared by the
defendant which were meant to circumvent Cross River Bank's
requirement and the requirement of other SBA-approved lenders
that prospective borrowers submit documentation to support the
certification the business was in operation on February 15,
2020.
With respect to defendant's receipt of kickbacks in
exchange for his work on the fraudulent PPP and EIDL
applications, the defendant laundered payments through bank
accounts he controlled but that were in the names of various
associates and more than 15 shell companies controlled by the
defendant, including the following entities:
Am Halal Meat, AMEX Financial Group, AMT Pizza, Sary
Stars, Black Diamond Sedan, Diva Productions, Vertical Payment
Processing, Holand Livestock, NR1 Transport, and Exclusive
Menswear. The payments were structured by the defendant and
made in a manner to conceal the nature and total amount of
payments and created the appearance that the payments were for
legitimate business purposes, including by containing memos
that indicated falsely that the payments were for
business-related purposes.
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THE COURT: Mr. Riley, by the way, some of the
evidence in this case was procured as a result of the issuance
of a federal search warrant as well, correct?
MR. RILEY: Correct, Your Honor.
THE COURT: Out of this court?
MR. RILEY: Correct, Your Honor.
THE COURT: A magistrate judge of this court signed
the search warrant. Who was the magistrate judge?
MR. RILEY: Your Honor, I believe it was Magistrate
Judge Coulson. I'm looking to Agent Parker to --
THE COURT: That's fine. It was a magistrate judge
of this court who authorized the search warrant.
MR. RILEY: Absolutely, yes, Your Honor.
THE COURT: I didn't mean to interrupt you. I'm
sorry.
MR. RILEY: No problem, Your Honor.
And the statement of facts goes on to discuss two specific
examples of fraudulent PPP loan applications submitted by the
defendant on Page 14 onto Page 15 there's a discussion of
fraudulent PPP loan for Nutscola Street Promotions, and based
on the false representations and fraudulent submissions made by
this defendant on March 26th, 2021, the loan was funded,
approximately $262,252 was distributed by Cross River Bank to a
Chase account controlled by coconspirator L.W., and the
Statement of Facts goes on to describe a $78,000 kickback
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payment or payments made by L.W. to the defendant.
Page 15 of the Stipulation of Facts onto Page 16 discusses
another fraudulent PPP loan that was part of the conspiracy.
This was for a purported business called Yazee, Inc., and based
on the false representations and fraudulent submissions made on
behalf of the owner of that purported business, the owner of
that business on March 22, 2021, received $250,723 from Cross
River Bank to a Wells Fargo account he controlled, and that
coconspirator thereafter paid the defendant a total amount of
$75,000 as a kickback in connection with that fraudulent PPP
loan.
In total, as set forth on Page 16, the defendant's
conspiracy with H.D. resulted in a disbursement of
$14,807,609.37 of fraudulently obtained funds in connection
with more than 85 fraudulent PPP loans.
Moreover, as noted, the defendant submitted numerous
fraudulent EIDL applications in connection with this scheme and
ultimately $3,093,670.50 in EIDL funds were disbursed in
connection with 57 fraudulent EIDL applications which contained
material misrepresentations concerning, among other things,
each purported business's existence, gross revenues, and
operating expenses.
As noted by Your Honor, the Stipulation of Facts concludes
with a discission of the federal search warrant that occurred
on April 29, 2022. Search warrants were conducted and executed
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at the office of AMEX Financial Group located at 1600 Hanover
Street in Baltimore, an apartment adjoining the office for AMEX
Financial Group, as well as the defendant's residence.
From the defendant's residence -- I'm sorry, from the
defendant's office and the apartment adjoining the defendant's
office, law enforcement seized numerous pieces of evidence
related to the defendant's scheme. Law enforcement seized over
90 hard copy files -- copies of files related to his submission
of PPP and EIDL applications for various entities. These files
contained large amounts of personal identifying information,
copies of driver's license, Social Security cards and numbers,
bank statements, as well as copies of checks and PPP
application paperwork. Some of the files contained fabricated
bank statements, tax documents submitted in connection with the
scheme.
The defendant executed the various fraud schemes discussed
in the Statement of Facts in part through the use of mobile
phones, computers, the Internet, multiple e-mail accounts, and
bank deposits and transfers, all of which involved interstate
wires, and the defendant and H.D. were in Maryland when they
transmitted the wire to execute the scheme.
THE COURT: Thank you very much, Mr. Riley.
(Conference at the bench. It is the policy of this
Court that every guilty plea and sentencing proceeding include
a bench conference concerning whether the defendant is or is
not cooperating.)
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THE COURT: I would note that the matter of the
forfeiture and the judgment is different from the matter of the
restitution figure in Paragraph 20. The restitution figure
relates to an overall restitution that should be ordered as to
Mr. Sary as well as other individuals. I know that this case
is related to at least one other case U.S. versus Walker,
22-0290, correct?
MR. RILEY: Correct. And in fact, Nutscola Street
Promotions is the entity that's involved with the Walker case,
that's correct, Your Honor.
THE COURT: Okay. But it's a different figure.
MR. RILEY: Yes, Your Honor. So the $17 million,
17.9 million of restitution, the $250,000, give or take, for
the Nutscola Street Promotions' PPP loan application, that
would be included in the $17.9 million joint and several, Your
Honor.
THE COURT: Okay. Thank you very much.
If you'll please stand, Mr. Sary.
Ms. Reamy, are there any modifications or additions to
that Statement of Facts?
MS. REAMY: No, Your Honor.
THE COURT: Mr. Sary, is that an accurate summary of
the facts in this case?
THE DEFENDANT: I'm sorry?
THE COURT: Is that an accurate summary of the facts
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in this case?
THE DEFENDANT: Yes, Your Honor.
THE COURT: And did you, in fact, commit the crime as
summarized by Mr. Riley on behalf of the Government?
THE DEFENDANT: Yes, Your Honor.
THE COURT: And do you still wish to plead guilty,
sir?
THE DEFENDANT: Yes.
THE COURT: Specifically, Mr. Sary, how do you plead
to the one-count Criminal Information in this case, guilty or
not guilty?
THE DEFENDANT: Guilty.
THE COURT: Ms. Reamy, is there any reason that you
know of why this Court not accept his plea of guilty?
MS. REAMY: No, Your Honor.
THE COURT: It is the finding of this Court in the
case of United States versus Ahmed Sary, Criminal Number
RDB-23-0344, that the defendant is fully competent and capable
of entering an informed plea and that the defendant is aware of
the nature of the charges and the relevant consequences of his
plea of guilty, and the Court further finds that his plea of
guilty on the advice of competent counsel with whose services
he is satisfied is a knowing and voluntary plea supported by an
independent basis in fact sustaining each of the essential
elements of the offense charged.
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The plea is to be accepted, and the defendant is now
adjudged guilty of conspiracy to commit wire fraud affecting
financial institutions in violation of 18 United States Code
§ 1349 and 1343 as set forth in the one-count Criminal
Information.
Mr. Sary, a written Presentence Investigation Report will
be prepared by Ms. Jessica Jackson, the U.S. Probation Officer,
to assist the Court in sentencing, and apparently that's
scheduled for immediately after these proceedings and Ms. Reamy
will be with you when you meet with Ms. Jackson. And after
Ms. Jackson prepares her report, both you and your attorney as
well as Government counsel can read the report and note any
objections to it, and she either will or won't make changes at
that time, and both you and Ms. Reamy will be afforded the
opportunity to speak on your behalf at the sentencing hearing.
So I will refer you to the U.S. Probation Office for a
Presentence Investigation Report.
Your date of sentencing here is -- was originally I think
going to be January 25, but now it is in fact February 1; is
that right? So date of sentencing will be February 1, 2024, at
11:00 a.m.
Ms. Jackson shall prepare her Presentence Investigation
Report by November 27th. Both Government counsel and your
counsel shall note any objections by December the 11th, and on
or before December 22nd, the probation officer will then file
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the report with the Court.
If either side desires to call any witnesses, you should
notify the opposing side as well as the Court by January the
18th. Sentencing memoranda are not required. This regular
sentencing order provides that if you're going to submit
sentencing memos, you should do so by January 18th. As I think
both Mr. Riley and Ms. Reamy know, I don't really -- I'm not a
stickler for that. This is a regular sentencing order from my
colleagues in terms of a time frame. I don't need to have the
sentencing memoranda two weeks prior, but I need to get it
within a week prior. I don't want to get it the night before.
But I'll sign this regular sentencing order to that effect.
Sentencing shall be on Thursday, February 1, 2024, at 11
a.m., and I have signed the regular sentencing order to that
effect, Ms. Maldeis.
Now, the defendant has been on release initially by order
of Chief Magistrate Judge -- I'm sorry, by order of Judge
Boardman, a District Court Judge, on May the 13th of 2022, and
then that was modified, I believe, in July of 2022 by
Magistrate Judge Coulson here, and the last entry I have is
that there was a temporary release of a passport for Mr. Sary.
That has now been surrendered back to the Clerk of the Court;
is that correct, Ms. Reamy?
MS. REAMY: Yes. The same day.
THE COURT: Does the Government have any reason to
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believe that this defendant represents a risk of flight or a
threat to the community, Mr. Riley?
MR. RILEY: No, Your Honor, and the Government would
ask that the Court continue this defendant on his current
conditions of release.
THE COURT: All right. The current release
conditions were summarized by Ms. Desiree Akuchie, the Senior
U.S. Probation Officer, with respect to the current conditions
of release, and he is currently in the third-party custody of
Isabella Sary. Is that his wife who's here in court? Is that
correct?
THE DEFENDANT: Yes, Your Honor.
MS. REAMY: Yes, Your Honor.
THE COURT: Good afternoon to you, Mrs. Sary. Good
afternoon.
MS. SARY: Good afternoon.
THE COURT: The same conditions of release will still
apply as have been existent, and Pretrial Services has
recommended that you may remain on release pending sentencing.
It's very important for you to continue to comply in that
fashion.
And, Mrs. Sary, if you have any difficulties in that
regard, I would basically indicate you call Ms. Reamy right
away. The point is don't do anything silly, Mr. Sary. This is
all being handled in a very civilized fashion.
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And Ms. Sary, in that manner, if you have any concerns
call Ms. Reamy and let her know, okay? Do you understand what
I'm saying?
MS. SARY: Yes. Yes, I do.
THE COURT: Okay. It's in your husband's best
interest that that be the case. So I'm certainly willing to
allow you to remain on release pending sentencing, and that's
also very important in terms of when you're ultimately
sentenced here, Mr. Sary, whether it's for five years or
anything above that up to nine and a half years, I will
certainly permit your voluntary surrender at a federal prison,
and you would be designated for a minimum security prison where
you have liberal visiting rights and your wife and your son --
is your son here as well? Is that correct?
THE DEFENDANT: Yes.
THE COURT: You're permitted to visit, and your
security clearance is definitely at such a level that it's
really in your interest to continue to comply and then
voluntarily surrender so that there are no handcuffs involved
and you report. But that all is contingent upon your
continuing to comply with the conditions of release. Do you
understand that?
THE DEFENDANT: Yes.
THE COURT: All right. Is there anything further
from the point of view of the Government on this matter,
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Mr. Riley?
MR. RILEY: Your Honor, I apologize. The only other
thing would be that the Due Process Protection Act
admonishment, the Government's -- the Rule 5 order, Your Honor.
THE COURT: Rule 5 in terms of Ms. --
MR. RILEY: I'm aware of my obligations.
THE COURT: Ms. Maldeis, do you have a standard
order? I think you should.
THE CLERK: Your Honor, there was already one
entered.
THE COURT: Was that already --
MR. RILEY: I apologize, Your Honor.
THE COURT: That's okay. That's all right.
MR. RILEY: I apologize, Your Honor.
THE COURT: I should have known, Ms. Maldeis is very
efficient and she would have brought that to my attention.
That has to do with essentially any information that's
exculpatory in nature needs to be provided to you under the
principles of the case known as Brady versus Maryland as well
as Giglio versus the United States under a particular rule and
that has already been handled previous court.
MR. RILEY: Yes, Your Honor. Thank you. I apologize
for that.
THE COURT: That's okay. No apology is necessary.
Made sure we confirmed that. Anything else, Mr. Riley, from
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your point of view?
MR. RILEY: No, thank you, Your Honor.
THE COURT: All right. Nice to see you again, and
Agent Parker, welcome back to our courtroom. Nice to see you
here, sir.
MR. PARKER: Thank you, sir.
THE COURT: Nice to see you.
And Ms. Reamy, anything further from your point of view?
MS. REAMY: No, Your Honor. Thank you.
THE COURT: All right. It's nice to see you as
always, and always nice to see you in a privately retained case
as well.
MS. REAMY: Good to see you.
THE COURT: So with that, this court stands -- I
believe that's it for the day. This court stands adjourned for
the day. Thank you all very much.
MR. RILEY: Thank you, Your Honor.
MS. REAMY: Thank you.
(The proceedings concluded at 3:33 p.m.)
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CERTIFICATE OF OFFICIAL REPORTER
I, Amanda L. Longmore, Registered Professional Reporter
and Federal Certified Realtime Reporter, in and for the United
States District Court for the District of Maryland, do hereby
certify, pursuant to 28 U.S.C. § 753, that the foregoing is a
true and correct transcript of the stenographically-reported
proceedings held in the above-entitled matter and that the
transcript page format is in conformance with the regulations
of the Judicial Conference of the United States.
Dated this 26th day of August 2025
-S-
______________________________________
AMANDA L. LONGMORE, RPR, CRR, FCRR
FEDERAL OFFICIAL COURT REPORTER
Case 1:23-cr-00344-RDB Document 118-1 Filed 09/19/25 Page 51 of 60
$100 [1] - 22:19
$14,807,609.37
[2] - 37:4; 41:14
$17 [1] - 43:12
$2,714,217.22 [1]
- 36:19
$250,000 [1] -
43:13
$250,723 [1] -
41:7
$262,252 [1] -
40:23
$3,093,670.50 [2]
- 37:11; 41:18
$3,627,489.22 [3]
- 20:17; 21:5,
15
$75,000 [1] -
41:10
$78,000 [1] -
40:25
$913,272 [1] -
38:8
$959,559.00 [1] -
37:14
1 [13] - 9:16, 22;
12:16, 18; 16:3;
17:11; 22:12;
35:12; 36:20;
37:7; 45:19;
46:13
10 [4] - 9:16, 22;
16:9; 27:16
11 [5] - 10:23;
29:21; 31:15;
35:12; 46:13
11(c [1] - 30:1
11(c)(1)(c [4] -
10:1; 18:1, 3;
22:14
114 [3] - 10:6, 12;
18:3
11:00 [1] - 45:21
11th [1] - 45:24
12 [5] - 20:12;
21:3; 30:18;
31:11, 18
13 [2] - 20:15;
38:11
1343 [3] - 18:19;
36:3; 45:4
1349 [4] - 6:9;
18:19; 36:3;
45:4
13th [1] - 46:18
14 [2] - 16:1;
40:19
15 [4] - 39:9, 15;
40:19; 41:2
16 [6] - 16:12;
20:12; 21:3;
35:12; 41:2, 12
1600 [1] - 42:1
17.9 [4] - 21:24;
22:25; 43:13, 15
18 [5] - 6:8; 18:18;
25:15; 36:3;
45:3
18th [2] - 46:4, 6
19 [1] - 24:13
1966 [1] - 9:5
1978 [2] - 11:24;
35:14
1st [2] - 12:24;
25:24
2 [1] - 38:20
20 [5] - 20:19;
21:22; 22:23;
38:18; 43:3
20-level [1] - 26:9
2005 [2] - 24:13,
23
2020 [5] - 7:13;
34:10; 35:15;
39:5, 10
2021 [2] - 40:22;
41:7
2022 [6] - 7:14;
34:10; 35:16;
41:25; 46:18
2023 [1] - 16:1
2024 [2] - 45:20;
46:13
21 [1] - 17:21
22 [1] - 41:7
22-0290 [1] - 43:7
22nd [1] - 45:25
23 [1] - 4:16
25 [1] - 45:19
26th [1] - 40:22
27th [1] - 45:23
29 [1] - 41:25
2:36 [1] - 2:2
3 [1] - 22:9
30 [4] - 22:11, 15;
36:21; 38:18
33 [1] - 26:20
3553 [1] - 25:16
3:33 [1] - 50:19
4 [1] - 30:12
46 [1] - 11:21
5 [6] - 5:25; 25:16;
26:2; 38:20;
49:4
50 [1] - 29:13
54 [1] - 29:13
57 [2] - 37:11;
41:19
6 [1] - 26:7
60 [3] - 10:5, 18;
18:3
7 [1] - 26:25
8 [1] - 27:8
85 [2] - 37:5;
41:15
9 [1] - 27:9
90 [1] - 42:8
940 [1] - 39:3
941 [1] - 39:3
944 [1] - 39:3
a.m [2] - 45:21;
46:14
abide [1] - 17:25
able [4] - 19:20;
27:23; 31:1
abolished [1] -
29:3
absolutely [1] -
40:13
accept [6] - 10:10,
22; 18:5, 22;
34:3; 44:14
acceptance [2] -
26:18; 35:8
accepted [1] -
45:1
access [1] - 30:6
acclimate [1] -
23:16
accomplish [2] -
34:15, 17
account [4] -
25:1, 22; 40:24;
41:8
accounts [3] -
21:8; 39:14;
42:18
accumulate [1] -
29:15
accurate [2] -
43:22, 25
accused [1] - 5:6
achieve [1] -
25:14
acid [2] - 14:18
acquit [1] - 31:16
act [1] - 7:7
Act [5] - 3:17; 7:8;
30:3, 8; 49:3
addiction [1] -
14:8
addition [2] -
37:13; 38:12
additions [1] -
43:19
addressed [1] -
29:22
addresses [1] -
33:14
adjoining [2] -
42:2, 5
adjourned [1] -
50:15
adjudged [2] -
18:23; 45:2
adjudication [1] -
18:24
adjustment [1] -
26:18
administer [1] -
11:14
Administration
[4] - 7:1, 8, 17;
35:20
admonishment
[1] - 49:4
advice [2] - 15:19;
44:22
advised [1] -
15:24
advisory [4] -
24:24; 25:2;
26:20; 27:24
affected [1] -
34:22
affecting [2] -
18:18; 45:2
afforded [2] -
8:18; 45:14
afternoon [9] -
2:22; 3:8, 19;
9:19; 18:23;
34:14; 47:14
age [1] - 11:20
agencies [1] -
30:5
agency [1] - 38:1
agent [1] - 40:10
Agent [3] - 2:24;
3:2; 50:4
ago [2] - 2:6;
24:13
agree [2] - 9:25;
10:2
agreed [9] - 10:4;
20:16, 25; 27:3,
13, 17; 29:8;
34:15, 17
agreement [31] -
9:14, 17, 20-21;
10:11, 20;
15:25; 16:7, 9,
15, 18, 24; 17:2,
6, 20-21; 18:2,
4, 6; 20:11;
21:4, 23; 22:10;
25:17; 26:3;
27:1; 29:22;
30:13; 35:13
AHMED [1] -
11:19
Ahmed [7] - 2:4;
3:9, 21; 11:16,
19; 35:14; 44:17
Aid [1] - 7:7
Akuchie [1] - 47:7
alcoholic [2] -
5:12; 14:11
Alexandria [1] -
37:1
allegations [1] -
8:2
alleged [5] - 6:9,
17, 23; 7:12;
34:16
allegedly [1] -
7:18
allow [1] - 48:7
almost [1] - 24:13
Amendment [1] -
32:4
American [4] -
19:6, 10, 16;
30:4
Amex [1] - 6:10
AMEX [4] - 37:23;
39:17; 42:1
ammunition [1] -
19:4
amount [11] -
20:16; 21:1, 5;
26:10; 36:22;
38:7, 18, 21;
39:21; 41:9
amounted [1] -
36:21
amounts [1] -
42:10
AMT [1] - 39:17
answer [2] -
13:14, 18
answers [1] -
13:14
anticipated [2] -
22:13; 26:19
apart [1] - 25:12
apartment [2] -
42:2, 5
apologize [4] -
49:2, 12, 14, 22
apology [1] -
49:24
appeal [5] - 10:25;
15:15; 29:23;
33:22, 24
appearance [5] -
2:8; 5:25; 6:2;
9:12; 39:22
application [5] -
7:11; 36:22;
Amanda L. Longmore, RPR, FCRR, Federal Official Court Reporter
Guilty Plea 10/18/25
52
38:21; 42:13;
43:14
applications [22]
- 6:12, 18, 20;
7:6; 36:5, 9,
14-15, 18;
37:12, 17, 20;
38:3, 22, 24;
39:2, 4, 13;
40:18; 41:17,
19; 42:9
applied [2] - 8:20;
24:24
apply [2] - 26:4;
47:18
appointed [4] -
8:9, 13, 21, 23
appointment [2] -
8:6, 12
appropriate [2] -
10:5; 21:14
approved [3] -
7:1; 35:20; 39:7
approving [1] -
27:3
April [4] - 7:13;
34:10; 35:15;
41:25
areas [1] - 2:11
argue [1] - 11:1
Arizona [1] - 9:5
arraignment [3] -
2:8; 9:12
artifice [1] - 7:16
assessment [1] -
22:18
Asset [1] - 21:13
assets [2] - 20:13,
22
assigned [1] - 4:3
assist [2] - 38:14;
45:8
assistance [3] -
19:22; 31:21;
36:17
Assistant [3] -
2:22; 16:1; 35:4
assisted [1] -
38:21
associated [1] -
37:18
associates [1] -
39:15
assurances [1] -
16:22
attachments [3] -
16:3, 8, 11
attempt [1] - 7:16
attempting [1] -
35:23
Case 1:23-cr-00344-RDB Document 118-1 Filed 09/19/25 Page 52 of 60
attendance [1] -
33:10
attention [1] -
49:16
attorney [8] -
5:16; 13:21;
15:9; 16:2, 15;
28:3; 30:6;
45:11
Attorney [4] -
2:23; 4:12; 16:1;
35:4
auspices [1] -
29:10
authorized [2] -
7:8; 40:12
available [1] -
21:8
aware [2] - 44:19;
49:6
balance [1] -
24:21
Baltimore [2] -
35:15; 42:2
Bank [6] - 6:24;
7:17; 11:9;
35:19; 40:23;
41:8
bank [6] - 36:12;
39:5, 13; 42:12,
14, 19
Bank's [1] - 39:6
base [1] - 26:8
based [2] - 40:20;
41:4
basic [1] - 34:25
basis [2] - 35:7;
44:24
beachfront [1] -
37:1
become [1] -
19:16
began [1] - 32:22
beginning [2] -
7:12; 35:15
behalf [5] - 2:23;
3:7; 41:6; 44:4;
45:15
bench [2] - 42:23
benefits [1] -
19:21
best [1] - 48:5
between [2] -
18:4; 29:13
beverage [2] -
5:12; 14:11
beyond [4] - 31:8;
33:2, 5; 34:12
binding [1] -
24:25
birth [1] - 11:23
Black [1] - 39:18
board [1] - 29:11
Boardman [1] -
46:18
Booker [3] -
24:12, 16, 20
boost [1] - 3:23
boosted [3] -
2:25; 3:14, 16
born [1] - 35:14
borrowers [3] -
6:19; 36:17;
39:8
Brady [1] - 49:19
brought [2] -
30:25; 49:16
burden [3] -
32:25; 33:1
Bureau [1] - 29:17
business [9] -
6:10; 37:23;
39:9, 23, 25;
41:4, 6
Business [4] -
7:1, 8, 17; 35:19
business's [1] -
41:21
business-
related [1] -
39:25
businesses [10] -
7:6; 36:5; 37:15,
18, 21; 38:1, 13,
15, 24; 39:3
calculation [2] -
25:11; 26:8
cannot [2] - 4:13;
28:22
capable [1] -
44:18
capacity [3] -
36:6; 38:2, 16
cards [1] - 42:11
CARES [1] - 7:8
case [41] - 2:3, 12;
4:3; 9:4, 15;
10:5; 11:14;
15:1, 5, 12, 16,
25; 16:23;
18:10; 24:12,
15, 20; 25:5;
26:5; 27:24;
28:1; 29:14;
30:6, 14, 23;
31:4, 12; 32:7;
33:21; 35:9;
40:2; 43:5, 9,
23; 44:1, 10, 17;
48:6; 49:19;
50:11
cases [1] - 24:9
catch [1] - 23:14
caused [1] - 35:25
causing [1] -
34:19
certain [8] - 2:15;
18:24; 19:19;
20:12; 23:4;
30:5, 12
certainly [6] -
10:10, 22;
17:25; 18:5;
48:6, 11
certification [1] -
39:9
changes [2] -
28:10; 45:13
characteristics
[1] - 25:19
charge [7] - 4:13;
6:3, 7; 12:7, 9,
13; 34:8
charged [4] -
4:11; 18:14;
36:20; 44:25
charges [7] -
7:19; 8:5; 15:2,
5, 9; 30:17;
44:20
chart [2] - 38:5, 9
Chase [1] - 40:24
checks [1] - 42:12
chief [1] - 46:17
choose [1] -
32:10
circumstances
[1] - 25:19
circumvent [1] -
39:6
citizen [4] - 19:6,
10-11, 16
citizens [2] - 4:16;
30:4
civil [1] - 18:25
civilian [1] - 23:16
civilized [1] -
47:25
clearance [1] -
48:17
Clerk [1] - 33:15
CLERK [11] -
11:17, 20, 22,
25; 12:3, 6, 9,
12, 15, 18; 49:9
clerk [1] - 46:22
clerk's [1] - 16:5
client [3] - 14:22;
17:3; 19:6
clothing [1] -
37:25
coconspirator [4]
- 35:17; 38:14;
40:24; 41:9
coconspirators
[3] - 35:24;
36:13; 38:14
Code [4] - 6:9;
18:19; 25:16;
45:3
colleagues [1] -
46:9
commerce [2] -
34:20; 36:1
commit [4] -
18:17; 34:18;
44:3; 45:2
committed [3] -
4:17, 20; 6:8
common [2] -
34:15, 18
communication
s [2] - 34:20;
36:1
community [2] -
4:16; 47:2
companies [1] -
39:15
company [1] -
37:25
compel [4] - 32:6;
33:9, 18
competent [3] -
14:22; 44:18, 22
complaint [2] -
2:5; 12:25
complete [2] -
17:2, 6
compliance [1] -
23:3
comply [3] -
47:20; 48:18, 21
computers [1] -
42:18
conceal [1] -
39:21
concerning [4] -
35:5; 36:7;
41:20; 42:24
concerns [1] -
48:1
concluded [1] -
50:19
concludes [1] -
41:23
conditions [8] -
23:4, 6, 20;
47:5, 7-8, 17;
48:21
conducted [1] -
41:25
Conference [1] -
42:23
conference [1] -
42:24
confirmed [1] -
49:25
Congress [1] -
30:4
conjunction [1] -
6:13
connection [12] -
30:14; 36:17;
37:4, 6, 11, 18,
21; 41:10, 14,
17, 19; 42:14
consenting [1] -
4:24
consequences
[3] - 23:25; 24:4;
44:20
consider [2] -
25:18; 32:24
consideration [1]
- 25:12
considered [1] -
25:15
consistent [1] -
10:23
consists [1] -
4:15
conspiracy [10] -
6:8; 18:17; 22:1;
34:11; 37:3, 10,
19; 41:3, 13;
45:2
conspired [2] -
7:15; 35:17
Constitution [1] -
32:5
constitutional [1]
- 24:22
constitutionality
[2] - 24:14, 16
constructive [1] -
23:14
contained [5] -
38:24; 39:4;
41:19; 42:10, 13
containing [1] -
39:23
context [1] -
24:24
contingent [1] -
48:20
continue [3] -
47:4, 20; 48:18
continuing [3] -
7:13; 35:15;
48:21
Amanda L. Longmore, RPR, FCRR, Federal Official Court Reporter
Guilty Plea 10/18/25
53
contributions [1]
- 22:7
controlled [5] -
37:15; 39:14;
40:24; 41:8
convict [1] -
31:15
convicted [4] -
20:1, 7; 31:11,
17
conviction [4] -
19:23; 20:4, 9;
27:20
cooperating [1] -
42:24
copies [3] - 42:8,
11
copy [8] - 11:25;
12:3; 14:25;
15:4; 17:19;
28:7; 42:8
Coronavirus [2] -
7:4, 7
correct [23] -
3:12; 4:25; 5:9;
6:14; 11:10;
12:19; 13:2,
5-6; 16:19;
19:14; 21:20;
40:3, 6; 43:7,
10; 46:23;
47:11; 48:14
correctly [2] -
3:20; 13:8
costs [2] - 36:8;
38:23
Coulson [2] -
40:10; 46:20
counsel [18] -
2:18, 20, 24;
8:5, 9, 11, 13,
21, 23-24; 28:3;
31:21; 44:22;
45:12, 23
count [6] - 14:25;
31:12; 34:9;
35:8; 44:10;
45:4
Count [3] - 12:16,
18; 36:20
counts [1] - 13:4
Court [23] - 8:7;
9:3; 15:24;
17:22; 20:25;
22:22; 23:4;
24:11, 14, 16,
20; 25:6, 23;
33:16; 44:14,
16, 21; 45:8;
46:1, 3, 18; 47:4
Case 1:23-cr-00344-RDB Document 118-1 Filed 09/19/25 Page 53 of 60
COURT [161] -
2:3; 3:1, 5, 11,
15, 22, 24; 4:1,
6, 9; 5:2, 5, 11,
15, 19; 6:7, 16,
23; 7:22; 8:4,
15, 17, 20; 9:8,
11; 10:10, 17,
22; 11:7, 12;
12:21; 13:4, 7,
10, 13, 18, 24;
14:1, 4, 7, 10,
13, 16, 19, 21,
25; 15:4, 8, 11,
14, 18, 21, 24;
16:11, 14, 18,
21; 17:1, 5, 9,
15, 17, 25; 18:9,
12, 16, 22; 19:2,
6, 9, 12, 15;
20:1, 6, 11, 18,
21; 21:2, 7, 12,
15, 20, 22; 22:4,
9, 18, 22; 23:2,
11, 19, 24; 24:3,
7; 25:5; 26:2, 7,
22, 25; 27:7, 16,
23; 28:6, 14, 17,
22; 29:2, 6, 21;
30:1, 11, 16, 21,
25; 31:6, 10, 15,
20, 25; 32:4, 10,
16, 21; 33:8, 12,
21; 34:2, 8;
35:3; 40:1, 5, 7,
11, 14; 42:22;
43:1, 11, 17, 22,
25; 44:3, 6, 9,
13, 16; 46:25;
47:6, 14, 17;
48:5, 16, 24;
49:5, 7, 11, 13,
15, 24; 50:3, 7,
10, 14
court [20] - 2:10;
4:10; 8:8, 13,
21, 23; 12:23;
24:8, 11; 40:5,
7, 12; 42:23;
46:22; 47:10;
49:21; 50:14
Court's [1] - 35:7
court-appointed
[4] - 8:9, 13, 21,
23
courthouse [1] -
2:12
courtroom [7] -
2:13, 16; 20:8;
31:1; 33:13, 18;
50:4
COVID-19 [1] -
6:17
created [2] -
36:10; 39:22
credit [4] - 23:8,
21; 29:14
crime [5] - 4:14;
18:13; 20:1, 7;
44:3
crimes [1] - 37:15
criminal [9] - 2:4;
9:25; 24:9; 27:1;
32:13; 33:1, 3;
44:17
Criminal [19] -
2:7, 9; 3:17;
4:11, 21, 25;
5:25; 6:4; 9:24;
10:2; 11:13;
15:1, 4; 31:12;
34:9, 16; 35:8;
44:10; 45:4
cross [3] - 31:23;
32:12
Cross [7] - 6:24;
7:17; 11:9;
35:18; 39:6;
40:23; 41:7
cross-
examination [1]
- 32:12
cross-examine
[1] - 31:23
cross-examined
[1] - 32:12
currency [1] -
20:17
current [3] - 47:4,
6, 8
custody [1] - 47:9
Dan [1] - 2:24
date [3] - 38:7;
45:18, 20
days [1] - 29:13
dealing [1] - 5:21
December [2] -
45:24
decide [1] - 32:17
decided [1] -
24:12
decline [1] - 32:1
DEFENDANT
[115] - 3:21, 23,
25; 5:1, 4, 10,
14, 18; 6:22;
7:21; 8:3, 14,
19; 9:7, 10;
10:9, 16, 21;
11:6, 19, 21, 24;
12:2, 5, 8, 11,
17, 20; 13:12,
17, 23, 25; 14:3,
6, 9, 12, 15, 18,
20; 15:3, 7, 10,
13, 17, 20, 23;
16:10, 13, 17,
20, 25; 17:8, 24;
18:8, 11, 15, 21;
19:1, 5, 25;
20:5, 10; 21:6;
22:3, 8, 17, 21;
23:1, 10, 18, 23;
24:6; 25:4; 26:1,
6, 21, 24; 27:6,
15, 22; 28:5, 13,
16, 21; 29:1, 5,
20, 25; 30:10,
15, 20, 24; 31:5,
9, 14, 19, 24;
32:3, 9, 15, 20;
33:7, 11, 20;
34:1, 7; 35:2;
43:24; 44:2, 5,
8, 12; 47:12;
48:15, 23
defendant [43] -
2:6; 3:7; 9:25;
11:15; 12:12;
20:16, 25; 33:1,
3; 35:14, 17, 24;
36:4, 11-13, 16,
22; 37:7, 13,
18-19; 38:13;
39:1, 6, 13, 16,
20; 40:19, 22;
41:1, 9, 16;
42:16, 20, 24;
44:18; 45:1;
46:16; 47:1, 4
defendant's [9] -
37:15; 38:11;
39:11; 41:12;
42:3-5, 7
defendants [2] -
21:25; 22:24
defense [3] -
31:22; 32:2;
33:10
definitely [2] -
26:22; 48:17
defraud [5] - 7:16,
23; 35:18;
36:20; 37:19
deletion [2] -
24:17, 21
deliberations [1] -
32:23
Department [1] -
30:8
deportation [2] -
19:12, 17
deposits [1] -
42:19
deprived [1] -
18:24
derived [1] - 37:7
describe [1] -
40:25
described [1] -
34:5
designated [1] -
48:12
Desiree [1] - 47:7
desires [1] - 46:2
desk [1] - 16:5
detail [1] - 37:16
determination [1]
- 4:14
determine [3] -
4:16, 19; 27:24
devise [1] - 34:21
devised [1] -
34:21
Diamond [1] -
39:18
different [5] -
16:21; 22:6;
28:19; 43:2, 11
difficulties [1] -
47:22
disaster [1] - 6:19
Disaster [2] -
7:11; 35:22
disbursed [1] -
41:18
disbursement [3]
- 37:3, 10;
41:13
discission [1] -
41:24
discovery [1] -
30:6
discretion [1] -
2:13
discuss [2] -
16:15; 40:17
discussed [8] -
5:5, 16; 15:8,
11; 26:4; 37:16;
42:16
discusses [1] -
41:2
discussing [1] -
10:24
discussion [2] -
38:10; 40:19
dismiss [1] -
12:25
dismissed [1] -
13:5
distinct [1] - 24:9
distributed [1] -
40:23
District [4] - 4:12;
7:14; 35:16;
46:18
Diva [1] - 39:18
documentation
[1] - 39:8
documents [1] -
42:14
done [1] - 15:22
doubt [4] - 31:8;
33:2, 5; 34:13
down [3] - 2:15;
16:5; 21:11
downward [1] -
26:17
driver's [1] -
42:11
drugs [3] - 5:12;
14:8, 11
Dubai [1] - 36:23
Due [1] - 49:3
duly [1] - 11:16
during [4] - 5:21;
6:13, 16; 7:3
e-mail [1] - 42:18
early [1] - 29:17
Economic [1] -
7:10
economic [3] -
6:19; 7:7; 35:22
educational [1] -
19:22
effect [2] - 46:12,
15
effectively [1] -
25:2
efficient [1] -
49:16
effort [1] - 16:22
Egypt [3] - 36:23,
25; 37:2
EIDL [13] - 36:4,
18; 37:11, 20;
38:8, 12, 15;
39:12; 41:17-19;
42:9
EIDLs [1] - 35:22
either [6] - 18:2;
25:20; 28:9;
45:13; 46:2
elected [1] - 32:2
elements [4] -
34:11, 13, 25;
44:25
employ [4] - 8:5,
11, 24
Amanda L. Longmore, RPR, FCRR, Federal Official Court Reporter
Guilty Plea 10/18/25
54
employees [2] -
36:8; 38:23
end [1] - 27:13
enforcement [2] -
42:6
engage [1] -
35:18
engaged [2] -
34:10; 38:13
English [1] - 14:5
entered [1] -
49:10
entering [2] -
34:3; 44:19
enterprise [1] -
34:24
entire [1] - 6:4
entities [2] -
39:16; 42:9
entity [2] - 38:6;
43:9
entry [1] - 46:20
essential [1] -
44:24
essentially [11] -
5:24; 7:4, 9-10,
12, 23; 20:21;
21:3; 26:8;
29:13; 49:17
establish [2] -
21:4; 35:7
estimate [1] -
28:19
evidence [5] -
15:12; 32:17,
19; 40:2; 42:6
exactly [1] - 28:22
examination [1] -
32:12
examine [1] -
31:23
examined [1] -
32:12
example [3] -
19:21; 29:7, 14
examples [1] -
40:18
exchange [4] -
36:17; 38:16,
18; 39:12
exclusive [2] -
37:25; 39:19
exculpatory [1] -
49:18
execute [4] - 7:15;
35:23; 42:21
executed [2] -
41:25; 42:16
executing [1] -
35:23
Case 1:23-cr-00344-RDB Document 118-1 Filed 09/19/25 Page 54 of 60
Exhibit [5] - 9:15,
22; 16:3; 17:11;
35:12
exist [2] - 36:6;
38:16
existed [1] - 38:2
existence [1] -
41:21
existent [1] -
47:18
expenses [1] -
41:22
explain [1] - 29:6
explained [1] -
12:7
expose [1] - 26:22
extensive [1] -
27:2
extent [1] - 19:15
fabricated [2] -
36:11; 42:13
face [2] - 19:17;
20:2
fact [9] - 5:5;
16:18; 18:13;
26:2; 38:2; 43:8;
44:3, 24; 45:19
factor [2] - 20:14;
27:3
factors [4] -
25:12, 15, 18,
22
Facts [7] - 37:16;
38:6; 40:25;
41:2, 23; 42:17;
43:20
facts [6] - 32:18;
35:5, 11; 40:17;
43:23, 25
factual [1] - 35:7
fairly [1] - 8:4
false [17] - 6:11,
18-19; 7:18,
24-25; 13:16;
36:4, 6, 9, 14;
37:20; 38:25;
39:2, 4; 40:21;
41:5
falsely [2] - 13:14;
39:24
far [3] - 13:22
Fargo [1] - 41:8
fashion [2] -
47:21, 25
FBI [1] - 2:24
February [7] -
12:24; 25:23;
39:5, 9; 45:19;
46:13
Federal [6] - 5:25;
9:24; 10:1;
24:14, 22
federal [18] - 4:10;
10:6; 19:23;
23:8; 24:8, 11,
25; 25:7; 26:23;
29:3, 11-12;
40:3; 41:24;
48:11
federally [2] -
6:24; 34:22
fee [2] - 37:13;
38:20
felony [1] - 18:19
few [4] - 9:16;
34:3, 14; 35:3
Fifth [1] - 32:4
figure [5] - 20:19;
22:24; 43:3, 11
figures [1] - 39:1
file [3] - 30:7;
33:15; 45:25
filed [5] - 2:5, 7;
5:23; 13:1;
17:18
files [4] - 42:8, 13
filing [1] - 7:24
financial [14] -
6:10, 25; 8:21;
18:18; 21:8;
26:12; 34:22;
35:18; 37:6, 8,
23; 39:17; 42:3;
45:3
Financial [3] -
6:10; 37:24;
42:1
fine [3] - 4:1;
22:12; 40:11
finish [1] - 23:13
firearm [1] - 27:21
firearms [1] - 19:4
first [5] - 11:18;
20:12; 24:12;
25:10; 27:8
five [10] - 10:7,
19; 22:11;
27:11, 14, 17;
28:18, 23;
29:16; 48:9
flight [1] - 47:1
following [1] -
39:16
follows [1] - 35:13
force [1] - 18:9
foreign [2] -
34:20; 36:1
forfeiting [1] -
20:13
forfeiture [5] -
20:13, 21; 21:3;
43:2
form [2] - 4:22;
5:23
forms [4] - 8:1;
36:10, 12; 39:2
forth [9] - 9:3, 20;
15:25; 16:23;
17:2, 6; 41:12;
45:4
fortunately [1] -
19:16
forward [1] -
24:23
four [1] - 29:10
Four [1] - 36:24
frame [1] - 46:9
fraud [5] - 6:8;
18:18; 34:18;
42:16; 45:2
fraudulent [28] -
6:11, 18-19;
7:25; 35:21;
36:4, 10, 18;
37:5, 17, 20;
38:12, 18,
20-21, 25; 39:2,
5, 12; 40:18,
20-21; 41:3, 5,
10, 15, 17, 19
fraudulently [3] -
36:23; 37:4;
41:14
free [1] - 10:14
Freedom [2] -
30:3, 8
freely [1] - 18:13
front [1] - 4:19
fully [5] - 3:15, 22;
15:8, 18; 44:18
funded [2] - 38:7;
40:22
funds [9] - 6:20;
7:9; 36:23; 37:4,
11, 14; 38:12;
41:14, 18
furthermore [3] -
20:11; 31:20;
33:8
future [1] - 20:7
gain [1] - 22:13
Gall [1] - 25:6
game [1] - 23:14
gather [3] - 6:3,
12; 26:4
general [2] - 7:19;
28:12
Giglio [1] - 49:20
given [3] - 15:19;
28:19; 34:5
glad [1] - 35:10
goal [1] - 25:13
goals [1] - 25:14
government [1] -
30:5
Government [41]
- 2:23; 4:13;
9:15, 17, 20-21;
10:4, 19, 25;
11:9; 12:1, 25;
16:2; 17:3, 7,
10, 13; 18:4;
20:22, 24; 22:5;
27:10, 12; 28:3;
29:23; 31:7;
32:6, 25; 33:1,
4, 12, 18; 34:12;
35:6, 12; 44:4;
45:12, 23;
46:25; 47:3;
48:25
Government's [2]
- 34:13; 49:4
gradually [1] -
2:17
graduate [1] -
14:2
grand [2] - 4:15;
5:8
greater [1] - 25:14
gross [3] - 26:12;
37:7; 41:21
grossly [2] -
38:22
Group [3] - 6:11;
37:24; 42:1
group [2] - 39:17;
42:3
guess [1] - 2:7
guideline [4] -
25:9; 26:7; 27:9,
24
Guidelines [3] -
24:15, 22, 24
guidelines [8] -
24:17; 25:11;
26:3, 20
guilt [3] - 31:8;
33:2, 5
guilty [37] - 5:21;
9:18, 23; 10:10,
14, 22; 11:13;
12:17; 14:22;
15:16; 16:23;
18:10, 12-13,
17, 23; 19:20;
24:1, 5; 30:7,
17; 33:22; 34:3,
9; 35:1, 8;
42:23; 44:6,
10-12, 14,
21-22; 45:2
H.D [8] - 35:17;
36:11; 38:14,
19, 21, 25;
41:13; 42:20
Halal [2] - 37:24;
39:17
half [8] - 10:7, 13;
27:4, 11, 18;
28:18, 23; 48:10
handcuffs [1] -
48:19
handled [2] -
47:25; 49:21
Hanover [1] - 42:1
hard [1] - 42:8
harsher [1] - 20:8
headquartered
[1] - 6:25
hear [2] - 31:22;
35:10
hearing [4] - 4:5,
18; 8:25; 45:15
help [1] - 23:15
high [3] - 13:25;
14:1
highly [1] - 8:8
himself [1] -
37:13
history [3] -
25:19; 27:1
Holand [1] - 39:19
hold [1] - 4:6
holdings [1] - 9:4
Honor [50] - 2:22,
25; 3:8, 13;
5:10; 6:6, 15;
11:11; 13:3, 6;
14:24; 17:4, 14,
16; 19:11;
20:15, 20, 24;
21:10; 23:23;
24:2; 28:16;
31:19; 35:2, 11;
40:4, 6, 9, 13,
16; 41:23;
43:10, 12, 16,
21; 44:2, 5, 15;
47:3, 12-13;
49:2, 4, 9, 12,
14, 22; 50:2, 9,
17
hotels [1] - 36:24
housing [1] -
19:21
hurry [1] - 13:20
husband's [1] -
48:5
identify [1] - 2:20
Amanda L. Longmore, RPR, FCRR, Federal Official Court Reporter
Guilty Plea 10/18/25
55
identifying [1] -
42:10
illness [1] - 14:8
immediately [1] -
45:9
impeachment [1]
- 32:11
implemented [1] -
6:16
important [4] -
13:18; 27:2;
47:20; 48:8
impose [1] -
25:13
imposed [5] -
25:20; 28:18;
33:23
imposes [1] -
25:23
imprisonment [5]
- 5:7; 10:13, 19;
22:11, 15
inability [1] - 8:22
Inc [1] - 41:4
incarceration [4]
- 10:6, 18; 27:4,
18
inclined [3] -
10:12, 17; 18:1
include [2] -
25:18; 42:23
included [6] -
7:10, 23; 36:6,
9; 39:1; 43:15
including [6] -
7:25; 15:12;
36:24; 39:2, 16,
23
increase [5] -
26:9, 12
incrimination [1]
- 32:5
independent [2] -
35:7; 44:24
indicate [1] -
47:23
indicated [5] -
5:20; 8:10; 9:1;
18:1; 39:24
indicates [2] -
4:23; 26:25
indicted [1] - 5:8
indictment [3] -
4:22, 24; 5:23
indigency [1] -
8:22
individuals [2] -
25:22; 43:5
induce [1] - 16:22
inflated [2] -
Case 1:23-cr-00344-RDB Document 118-1 Filed 09/19/25 Page 55 of 60
38:22
influence [2] -
5:12; 14:10
information [10] -
12:1, 4, 6, 16,
19; 30:5; 36:7,
20; 42:10; 49:17
Information [17] -
2:7, 9; 4:11, 22,
25; 6:4; 11:13;
15:1, 5; 30:3, 8;
31:12; 34:9, 16;
35:9; 44:10;
45:5
informed [1] -
44:19
initial [5] - 2:8;
5:24; 6:1; 9:12;
12:25
injury [2] - 6:19;
35:22
Injury [1] - 7:10
innocence [1] -
33:4
innocent [1] -
31:7
input [1] - 31:2
inquire [1] - 2:18
inquired [1] - 8:6
institution [5] -
6:25; 18:18;
26:13; 34:23;
35:18
institutions [3] -
37:6, 8; 45:3
instructed [1] -
32:22
instruction [1] -
25:7
insured [2] - 6:25;
34:22
intelligent [1] -
5:20
intending [1] -
34:21
interest [3] -
37:22; 48:6, 18
Internal [2] - 7:25;
36:10
Internet [1] -
42:18
interrupt [1] -
40:14
interstate [4] -
34:20; 36:1;
38:4; 42:19
introduced [3] -
9:15, 21; 17:10
Investigation [5] -
11:3; 27:25;
45:6, 17, 22
involved [7] -
7:24; 22:1; 27:9;
34:18; 42:19;
43:9; 48:19
involves [1] - 23:3
involving [1] -
26:11
IRS [3] - 36:10;
38:25; 39:2
Isabella [1] -
47:10
issuance [2] -
33:9; 40:2
issue [1] - 19:13
issued [1] - 33:16
issues [2] - 19:17;
27:9
it'd [1] - 23:11
Jackson [9] - 4:4,
7; 11:4; 28:2,
10; 45:7, 10-11,
22
January [8] -
7:13; 24:13, 23;
34:10; 35:16;
45:19; 46:3, 6
Jersey [1] - 6:25
Jessica [4] - 4:4,
7; 28:1; 45:7
jobs [1] - 19:20
joined [1] - 34:24
joint [6] -
21:16-18, 25;
22:24; 43:15
Judge [3] - 40:10;
46:17, 20
judge [8] - 2:13;
4:19; 20:8; 40:7,
11; 46:17
judges [4] -
24:25; 25:1, 7
judgment [5] -
20:16; 21:1, 4,
16; 43:2
Julie [2] - 3:9;
16:2
July [1] - 46:19
jurors [5] - 30:19,
25; 31:11, 15,
18
jury [9] - 4:15;
5:8; 15:16;
30:14, 18, 22;
31:3; 32:22
Justice [2] - 3:17;
30:9
keep [3] - 5:2;
19:19, 21
key [1] - 24:10
kickback [6] -
36:16; 38:11,
17; 40:25; 41:10
kickbacks [4] -
36:19, 21;
37:13; 39:11
kind [7] - 5:13;
14:8, 11, 16;
21:16; 22:15;
33:24
Kitchen [1] - 37:2
knowing [2] -
5:19; 44:23
knowingly [2] -
7:14; 35:24
known [5] - 7:7;
8:7; 30:2; 49:15,
19
L.W [2] - 40:24;
41:1
language [1] -
14:5
large [1] - 42:10
last [5] - 2:6;
11:18; 28:14;
46:20
laundered [1] -
39:13
law [4] - 29:8;
30:3; 42:6
lawyer [1] - 8:8
lawyers [1] - 11:1
leader [1] - 26:16
least [2] - 37:3;
43:6
legitimate [4] -
36:6; 38:2, 16;
39:23
lender [2] - 7:2
lenders [3] - 7:17;
35:20; 39:7
less [2] - 10:18
letter [14] - 9:21;
15:25; 16:6,
8-9, 15, 24;
17:2, 6, 20-21;
25:17; 26:3;
30:13
level [7] - 26:8,
10-11, 13-14,
19; 48:17
levels [1] - 26:17
liability [4] -
21:17, 19, 25
liberal [1] - 48:13
license [1] - 42:11
licenses [1] -
19:19
life [1] - 23:17
likewise [2] -
37:10; 39:4
lists [1] - 38:6
Livestock [1] -
39:19
Loan [1] - 7:11
loan [19] - 6:12,
18, 20; 7:6;
36:5, 16, 22;
37:13, 20; 38:6,
11, 18; 40:18,
20, 22; 41:3, 11;
43:14
loans [8] - 7:5;
19:22; 35:22;
37:5; 38:8, 15;
41:15
located [1] - 42:1
location [1] - 38:5
look [1] - 31:1
looking [2] - 16:7;
40:10
lose [3] - 19:2
loss [2] - 22:13;
26:9
lost [1] - 19:22
low [1] - 27:13
luxury [1] - 36:24
magistrate [6] -
40:7-9, 11;
46:17, 20
mail [1] - 42:18
main [1] - 6:24
Maldeis [10] -
5:23; 11:14;
12:21; 16:4;
17:10, 18;
46:15; 49:7, 15
manager [1] -
26:15
mandatory [2] -
24:19, 21
manner [3] - 7:22;
39:21; 48:1
March [3] - 35:14;
40:22; 41:7
marked [1] - 16:2
Maryland [7] -
4:12; 7:14;
35:15; 38:4;
42:20; 49:19
masking [1] -
2:10
masks [1] - 2:11
material [1] -
41:20
matter [13] - 3:12;
4:10, 23; 5:16,
22; 6:1; 8:9;
9:18; 17:18;
23:11; 43:1;
48:25
matters [1] -
20:13
maximum [3] -
22:10, 12
mean [1] - 40:14
meaning [1] -
24:24
means [10] - 7:22;
10:11; 21:22;
22:4, 6; 26:14;
29:6, 14; 34:19;
35:25
meant [3] - 23:13,
15; 39:6
meat [1] - 37:24
Meat [2] - 37:25;
39:17
medication [4] -
5:12; 14:11, 13,
17
meet [3] - 4:5;
28:6; 45:10
meeting [1] - 11:5
members [1] -
3:16
memoranda [2] -
46:4, 10
memos [2] -
39:23; 46:6
menswear [2] -
37:25; 39:20
mental [1] - 14:8
mentioned [3] -
22:22; 23:2;
26:3
might [6] - 19:19;
20:7; 22:6;
28:18; 29:8, 15
million [7] -
21:24; 22:12,
25; 37:7; 43:12,
15
minimum [1] -
48:12
minutes [2] -
34:14; 35:4
Miranda [1] - 9:5
misrepresentati
ons [1] - 41:20
missed [1] - 20:18
mistrial [1] -
31:16
mobile [1] - 42:17
modifications [1]
- 43:19
modified [1] -
46:19
moments [2] -
9:16; 34:4
Amanda L. Longmore, RPR, FCRR, Federal Official Court Reporter
Guilty Plea 10/18/25
56
money [7] - 7:18;
20:16, 25; 21:4,
8; 22:5
monitored [1] -
23:4
monthly [2] -
36:8; 38:23
months [2] - 18:3;
29:16
months' [3] -
10:6, 12, 18
moreover [1] -
41:16
MR [30] - 2:22;
3:4; 6:15; 11:11;
13:3, 6; 17:14;
20:15, 20, 24;
21:10, 13, 18;
35:11; 40:4, 6,
9, 13, 16; 43:8,
12; 47:3; 49:2,
6, 12, 14, 22;
50:2, 6, 17
MS [24] - 3:8, 13;
4:4, 8; 6:6;
12:14; 13:9;
14:24; 17:4, 16;
19:8, 11, 14;
21:21; 24:2;
43:21; 44:15;
46:24; 47:13,
16; 48:4; 50:9,
13, 18
multiple [5] -
36:24; 37:20;
38:3, 7; 42:18
multistep [1] -
25:10
must [1] - 22:18
name [4] - 3:9, 20;
11:18; 13:8
names [2] - 33:13;
39:14
narcotic [1] - 14:8
naturalized [2] -
19:9, 11
nature [7] - 7:19;
8:2, 4; 25:19;
39:21; 44:20;
49:18
necessary [2] -
25:14; 49:24
need [3] - 17:12;
46:9
needs [1] - 49:18
never [3] - 32:25;
33:2
New [1] - 6:25
new [1] - 31:16
next [3] - 12:24;
Case 1:23-cr-00344-RDB Document 118-1 Filed 09/19/25 Page 56 of 60
29:10; 38:10
nice [10] - 3:1, 5,
17; 50:3, 7, 10
night [1] - 46:11
nine [8] - 10:7, 13;
27:4, 11, 17;
28:18, 23; 48:10
nine-and-a-half-
year [3] - 27:11;
28:18, 23
none [1] - 38:1
normal [1] - 2:17
normally [2] -
4:15; 14:13
note [11] - 2:4;
9:14; 11:8;
12:22; 19:18;
21:23; 28:4, 9;
43:1; 45:12, 24
noted [6] - 22:9;
24:20; 27:7, 16;
41:16, 23
notes [6] - 9:22;
10:24; 17:21;
22:23; 27:8
notice [1] - 11:8
notify [1] - 46:3
noting [1] - 25:7
November [1] -
45:23
NR1 [1] - 39:19
number [3] - 2:4;
36:7; 44:17
Number [1] - 9:15
numbers [2] -
38:22; 42:11
numerous [4] -
35:21; 36:4;
41:16; 42:6
Nutscola [3] -
40:20; 43:8, 14
oath [2] - 11:14;
13:11
objections [4] -
28:4, 9; 45:13,
24
obligations [1] -
49:6
obtain [3] - 7:5,
18; 35:21
obtained [3] -
36:23; 37:4;
41:14
obtaining [2] -
38:12, 15
obviously [3] -
14:4; 22:14;
27:12
occasions [1] -
36:24
occurred [1] -
41:24
offense [14] -
4:18, 20; 5:6;
18:16, 19, 23;
22:11; 25:20;
26:8, 11, 19;
34:25; 37:9;
44:25
offer [1] - 34:14
office [5] - 19:3;
42:1, 5
Office [2] - 23:5;
45:16
office's [1] - 21:13
officer [1] - 45:25
Officer [5] - 4:2;
11:4; 28:1; 45:7;
47:8
officials [1] - 11:9
one [24] - 3:16;
4:6; 5:7; 6:23;
10:12, 18;
14:25; 22:4;
28:14; 29:9, 18;
31:12, 15;
32:13; 34:9;
35:8; 37:8; 43:6;
44:10; 45:4;
49:9
one-count [6] -
14:25; 31:12;
34:9; 35:8;
44:10; 45:4
one-third [2] -
29:9, 18
open [1] - 37:1
operating [1] -
41:22
operation [1] -
39:9
opinion [1] - 25:2
opinions [1] -
24:10
opportunity [4] -
16:14; 28:4, 24;
45:15
opposing [1] -
46:3
order [10] - 7:5;
22:23; 46:5, 8,
12, 14, 16-17;
49:4, 8
ordered [1] - 43:4
ordinarily [1] -
4:12
organizer [1] -
26:16
original [2] - 16:6
originally [2] -
2:5; 45:18
otherwise [2] -
19:17; 37:22
outline [1] - 24:11
outlines [1] - 26:7
overall [2] - 22:1;
43:4
own [6] - 4:13;
18:12; 27:21;
31:25; 32:2;
38:13
owned [1] - 37:21
owner [2] - 41:6
p.m [2] - 2:2;
50:19
packing [1] -
37:24
Page [8] - 16:9,
12; 38:11;
40:19; 41:2, 12
Pages [1] - 35:12
paid [1] - 41:9
pandemic [3] -
6:13, 17; 7:3
panel [1] - 3:17
paper [1] - 7:24
paperwork [1] -
42:13
Paragraph [20] -
9:16, 22; 10:23;
17:21; 20:15,
19; 21:22; 22:9,
23; 25:16; 26:2,
7, 25; 27:8, 16;
29:21; 30:1, 12;
43:3
Paragraphs [2] -
20:12; 21:3
Parker [4] - 2:24;
3:2; 40:10; 50:4
PARKER [2] - 3:4;
50:6
parole [6] - 20:2;
29:3, 10
part [3] - 32:1;
41:3; 42:17
participate [1] -
30:22
participated [1] -
7:2
particular [3] -
4:18; 24:17;
49:20
parties [1] - 2:19
parties' [1] -
35:12
party [3] - 17:22;
18:6; 47:9
passed [1] - 30:3
passport [1] -
46:21
past [1] - 20:2
Paul [3] - 2:23;
16:1; 35:4
Pause [1] - 8:16
pay [2] - 8:22;
22:18
Paycheck [3] -
6:11; 7:2; 35:21
payment [3] -
38:17; 39:18;
41:1
payments [7] -
36:16; 39:13,
20, 22, 24; 41:1
payroll [3] - 36:8;
38:23; 39:1
penalties [1] -
22:14
pending [2] -
47:19; 48:7
people [4] - 22:6;
30:18; 33:12, 18
percent [4] -
36:21; 38:18, 20
perhaps [3] -
7:23; 15:15;
23:20
period [2] - 23:12;
29:16
perjury [1] - 13:15
permit [1] - 48:11
permits [2] -
19:20; 30:4
permitted [2] -
27:20; 48:16
persist [1] - 30:17
person [2] - 22:4,
6
personal [2] -
25:18; 42:10
persons [4] -
33:14, 17;
34:15, 17
phones [1] -
42:18
pictures [1] - 36:2
pieces [1] - 42:6
pizza [1] - 39:17
placed [1] - 12:9
places [1] - 16:16
plan [2] - 34:16,
18
plea [46] - 5:21;
9:14, 18, 20;
10:10, 14, 20,
23; 11:13;
12:18; 14:22;
15:25; 16:7, 9,
15, 24; 17:2, 6,
20-21; 18:2, 22;
19:20; 20:11;
21:23; 22:9, 14;
23:25; 24:4;
25:17; 26:2;
29:21; 30:12,
17; 34:3; 35:8,
13; 42:23;
44:14, 19, 21,
23; 45:1
plead [6] - 12:15;
16:23; 18:10;
30:17; 44:6, 9
pleading [6] -
9:23; 18:12, 17;
30:7; 34:8; 35:1
Plexiglass [3] -
2:14, 17
point [9] - 17:12,
15; 21:9; 24:23;
25:9; 47:24;
48:25; 50:1, 8
policies [1] - 2:10
policy [1] - 42:23
portion [2] -
17:12; 38:19
portions [1] - 2:16
possess [1] -
27:21
possibility [2] -
15:15; 20:3
possible [2] -
23:25; 24:4
potential [2] -
19:17; 21:24
PPP [24] - 7:3;
35:21; 36:5, 9,
13, 18; 37:4, 20;
38:7, 12, 15, 24;
39:2, 4, 12;
40:18, 20; 41:3,
10, 15; 42:9, 12;
43:14
PPP/EIDL [1] -
37:14
predict [1] - 28:22
preliminary [2] -
4:18; 8:25
prepare [2] - 28:7;
45:22
prepared [11] -
6:11, 18; 11:3;
27:25; 28:2;
35:6; 36:4, 12;
38:25; 39:5;
45:7
prepares [1] -
45:11
present [1] - 3:10
Presentence [5] -
Amanda L. Longmore, RPR, FCRR, Federal Official Court Reporter
Guilty Plea 10/18/25
57
11:3; 27:25;
45:6, 17, 22
presentence [2] -
28:11, 25
presiding [1] -
2:13
presumably [1] -
21:7
presume [1] -
25:8
presumed [1] -
31:7
pretenses [1] -
7:18
Pretrial [1] - 47:18
previous [1] -
49:21
previously [3] -
2:10; 8:10;
24:18
principles [2] -
9:3; 49:19
prison [11] - 10:6,
14; 23:5, 7-8,
13, 21; 26:23;
48:11
Prisons [1] -
29:17
privately [3] -
3:11, 18; 50:11
privilege [1] -
32:5
probable [3] -
4:14, 17, 19
Probation [7] -
4:2; 11:4; 23:5;
28:1; 45:7, 16;
47:8
probation [3] -
20:2; 45:25
problem [1] -
40:16
Procedure [3] -
6:1; 9:24; 10:2
proceed [4] -
9:11, 13; 11:13;
14:22
proceeding [2] -
4:21; 42:23
Proceedings [1] -
8:16
proceedings [4] -
11:5; 17:11;
45:9; 50:19
Process [1] - 49:3
process [7] - 4:9;
23:14; 24:7, 11;
25:10; 27:14;
28:12
processing [1] -
Case 1:23-cr-00344-RDB Document 118-1 Filed 09/19/25 Page 57 of 60
39:19
procure [1] - 6:20
procured [1] -
40:2
Productions [1] -
39:18
proffer [1] - 9:19
Program [3] -
6:12; 7:3; 35:21
program [7] -
6:16, 21; 7:3-5,
9, 11
promises [1] -
16:22
promotions [1] -
40:20
Promotions [1] -
43:9
Promotions' [1] -
43:14
pronouncing [2] -
3:19; 13:8
proof [1] - 34:13
property [1] -
36:25
prosecution [3] -
4:24; 13:15
prospective [1] -
39:8
protect [1] - 22:14
protected [1] -
2:16
Protection [4] -
6:12; 7:2; 35:21;
49:3
prove [6] - 31:8;
33:2, 4-5;
34:12; 35:6
provide [1] - 7:9
provided [6] -
12:1; 22:10;
25:7; 36:11;
38:25; 49:18
provides [4] -
9:24; 20:12;
27:17; 46:5
provisions [1] -
24:21
public [3] - 2:11;
19:3, 21
punishment [1] -
5:6
purchase [1] -
36:25
purported [15] -
6:10; 36:5;
37:14, 21,
23-25; 38:1, 13,
15, 24; 39:3;
41:4, 6, 21
purpose [2] -
34:23; 35:23
purposes [3] -
17:11; 39:23, 25
pursuant [4] -
9:19, 23; 25:10;
34:11
put [1] - 32:17
putting [1] - 32:18
qualifying [1] -
7:5
questions [2] -
13:14, 19
quite [2] - 2:6, 14
radio [1] - 34:19
ran [1] - 6:9
range [14] - 10:1,
25; 11:2; 18:3;
25:9; 27:11, 13,
17, 24; 28:18,
23; 29:8, 24
RDB-23-0344 [2] -
2:4; 44:18
reached [1] - 9:17
read [4] - 12:6;
14:4; 16:14;
45:12
reading [1] - 6:4
ready [2] - 9:11;
11:12
really [2] - 46:7;
48:18
REAMY [22] - 3:8,
13; 4:4, 8; 6:6;
12:14; 13:9;
14:24; 17:4, 16;
19:8, 11, 14;
21:21; 24:2;
43:21; 44:15;
46:24; 47:13;
50:9, 13, 18
Reamy [38] - 3:9,
11; 4:2; 5:16;
6:3; 8:20; 12:12;
13:8, 21; 14:21;
15:9, 18; 16:2,
4, 16; 17:1, 9,
15, 19; 19:7;
21:20; 23:24;
27:12; 28:8;
30:22; 31:3;
33:15; 43:19;
44:13; 45:9, 14;
46:7, 23; 47:23;
48:2; 50:8
Reamy's [2] - 8:7;
28:19
reason [3] - 8:6;
44:13; 46:25
reasonable [6] -
25:9; 27:10;
31:8; 33:2, 5;
34:12
reasons [2] - 5:20
receipt [1] - 39:11
receipts [2] -
26:12; 37:8
receive [2] - 20:7;
38:17
received [8] -
11:25; 12:3;
14:25; 15:4;
33:17; 36:16;
37:14; 41:7
receiving [1] -
36:19
recently [1] - 14:7
recommend [2] -
27:10, 13
recommended [1]
- 47:19
recommends [1] -
27:12
record [5] - 2:21;
3:9; 11:18;
17:18; 32:13
records [3] - 7:25;
8:1; 38:25
Recovery [1] -
21:13
refer [1] - 45:16
reference [1] -
21:23
referenced [1] -
25:16
reflected [1] -
38:8
reflects [1] - 30:2
reflux [2] - 14:18
regard [4] - 5:17;
9:9; 33:6; 47:23
regular [5] -
14:16; 46:4, 8,
12, 14
related [4] -
39:25; 42:7;
43:6
relates [1] - 43:4
release [16] -
22:12; 23:2, 7,
12, 16, 20;
46:16, 21; 47:5,
9, 17, 19; 48:7,
21
released [1] -
29:17
relevant [1] -
44:20
relief [1] - 7:4
Relief [1] - 7:7
remain [2] -
47:19; 48:7
rendered [2] -
24:18; 25:2
Report [5] - 11:3;
27:25; 45:6, 17,
23
report [8] - 28:2,
7, 11, 25; 45:11;
46:1; 48:20
represent [2] -
3:9; 12:12
representation
[2] - 15:19; 35:5
representations
[3] - 36:14;
40:21; 41:5
represents [1] -
47:1
request [2] - 8:6;
30:8
require [2] - 5:8;
33:12
required [5] -
2:11; 9:1; 33:3;
46:4
requirement [2] -
39:7
residence [2] -
42:3
resident [1] -
35:14
respect [7] - 6:1;
7:9; 9:18; 24:8;
37:17; 39:11;
47:8
respected [1] -
8:8
responses [1] -
31:2
responsibility [1]
- 26:18
restaurant [1] -
37:1
restitution [8] -
20:19; 21:24;
22:23; 43:3, 13
result [8] - 18:24;
19:20, 23; 25:2;
27:19; 36:19;
37:8; 40:2
resulted [4] -
37:3, 10; 38:3;
41:13
retain [1] - 8:18
retained [4] -
3:12, 18; 8:10;
50:11
retrieve [1] - 16:4
retrofitted [1] -
2:14
return [5] - 12:23;
17:9; 22:19;
23:7; 25:23
Revenue [2] - 8:1;
36:10
revenue [1] - 36:8
revenues [1] -
41:21
review [2] - 28:4,
24
reviewed [1] -
9:14
reviewing [1] -
11:2
rights [10] - 5:8,
17; 9:8; 18:25;
30:2, 12, 14;
33:6; 34:5;
48:13
RILEY [28] - 2:22;
6:15; 11:11;
13:3, 6; 17:14;
20:15, 20, 24;
21:10, 13, 18;
35:11; 40:4, 6,
9, 13, 16; 43:8,
12; 47:3; 49:2,
6, 12, 14, 22;
50:2, 17
Riley [19] - 2:23;
3:1; 6:14; 11:7;
13:2; 16:1;
17:13; 20:14;
21:9; 28:7; 35:4,
10; 40:1; 42:22;
44:4; 46:7; 47:2;
49:1, 25
risk [1] - 47:1
River [7] - 6:24;
7:17; 11:9;
35:19; 39:6;
40:23; 41:8
road [1] - 21:11
routinely [1] -
36:9
rule [2] - 9:23;
49:20
Rule [4] - 5:25;
17:25; 49:4
Rules [3] - 5:25;
9:24; 10:1
run [1] - 19:3
S-a-r-y [1] - 11:19
Sary [43] - 2:4;
3:9, 19, 21-22;
4:9; 11:16, 19;
12:15, 24; 13:7,
10; 15:1; 16:7;
17:5, 20; 19:15;
Amanda L. Longmore, RPR, FCRR, Federal Official Court Reporter
Guilty Plea 10/18/25
58
23:3, 25; 24:3;
27:20; 29:2;
31:18; 33:6;
35:1, 14; 38:1,
17; 39:17; 43:5,
18, 22; 44:9, 17;
45:6; 46:21;
47:10, 14, 22,
24; 48:1, 9
SARY [2] - 47:16;
48:4
Sary's [1] - 37:2
satisfied [9] -
5:15; 12:13;
14:21; 15:18;
17:1, 5; 23:24;
24:3; 44:23
SBA [4] - 35:20;
38:5; 39:7
SBA-approved
[2] - 35:20; 39:7
scheduled [2] -
4:5; 45:9
scheme [15] -
7:16, 22; 34:21;
35:18, 24;
36:20; 37:7, 19;
38:11, 13;
41:17; 42:7, 15,
21
schemes [1] -
42:16
school [5] -
13:22, 24-25;
14:1
sealed [2] - 17:12,
17
search [5] - 40:3,
8, 12; 41:24
Seasons [1] -
36:25
seated [2] - 3:6;
35:3
second [1] - 4:6
section [1] -
38:10
sections [1] -
24:17
secured [1] - 21:7
security [3] - 7:7;
48:12, 17
Security [1] -
42:11
Sedan [1] - 39:18
see [16] - 3:1, 5;
28:7, 14; 31:1,
22; 33:17; 50:3,
7, 10-11, 13
seek [1] - 30:4
seized [3] - 20:22;
Case 1:23-cr-00344-RDB Document 118-1 Filed 09/19/25 Page 58 of 60
42:6
select [1] - 3:16
selected [1] -
30:19
selection [2] -
30:22; 31:3
self [1] - 32:5
self-
incrimination
[1] - 32:5
Senior [1] - 47:7
sent [2] - 23:8, 20
sentence [26] -
9:25; 10:1-3, 5,
12, 18, 25; 20:8;
22:10; 23:5, 13;
25:13, 20, 23;
27:3, 10, 13;
28:17, 23; 29:7,
15, 18, 23;
33:23
sentenced [2] -
11:2; 48:9
Sentencing [3] -
24:15, 22
sentencing [23] -
12:22; 22:19;
24:8, 11; 25:8,
14; 42:23; 45:8,
15, 18, 20;
46:4-6, 8, 10,
12-14; 47:19;
48:7
separate [3] -
21:16, 18; 23:11
September [1] -
16:1
serve [3] - 29:9,
18
served [2] - 23:9,
21
servers [1] - 38:5
Service [2] - 8:1;
36:10
services [4] -
6:10; 37:23;
38:19; 44:22
Services [1] -
47:18
set [10] - 9:3, 20;
12:24; 15:25;
16:23; 23:4;
35:11; 41:12;
45:4
sets [3] - 17:2, 6;
18:3
seven [1] - 26:9
several [6] -
21:16-18, 25;
22:24; 43:15
shall [3] - 45:22,
24; 46:13
shell [1] - 39:15
shifts [2] - 32:25;
33:3
shortly [1] - 9:22
show [1] - 8:21
side [4] - 18:2;
28:9; 46:2
sign [1] - 46:12
signals [1] - 36:2
signature [2] -
16:9, 12
signed [6] -
16:16, 19;
17:22; 18:6;
40:7; 46:14
signs [1] - 36:2
silly [1] - 47:24
similarly [1] -
25:21
situated [1] -
25:21
situation [1] -
15:11
six [5] - 27:4;
29:7, 15
six-year [3] - 29:7,
15
Small [4] - 7:1, 8,
16; 35:19
small [1] - 38:19
Social [1] - 42:11
someone [1] -
4:13
son [2] - 48:13
sophisticated [1]
- 26:14
sorry [8] - 5:2;
8:15; 12:2; 15:3;
40:15; 42:4;
43:24; 46:17
sought [1] - 8:12
sounds [1] - 36:2
Special [1] - 2:24
special [1] - 22:18
specific [4] - 9:23,
25; 10:3; 40:17
specifically [9] -
6:9; 9:16; 18:17;
24:20; 25:6;
29:22; 30:13;
32:23; 44:9
spell [1] - 11:17
stand [1] - 43:18
standard [1] -
49:7
stands [2] - 50:14
stars [2] - 38:1;
39:18
started [1] - 2:14
starting [1] - 25:9
state [4] - 11:17;
24:9; 29:4, 8
statement [4] -
9:1, 5; 40:17
Statement [3] -
40:25; 42:17;
43:20
statements [5] -
13:16; 36:12;
39:5; 42:12, 14
States [14] - 2:3;
6:9; 7:25; 18:19;
24:10, 12-13,
15; 25:6, 16;
35:19; 44:17;
45:3; 49:20
status [2] - 2:18;
8:7
statute [1] - 22:11
stay [1] - 36:24
steps [2] - 6:13;
21:14
stickler [1] - 46:8
still [7] - 2:12,
15-16; 25:1;
32:17; 44:6;
47:17
Stipulation [4] -
37:16; 38:6;
41:2, 23
stop [3] - 8:14;
9:2; 13:20
Street [4] - 40:20;
42:2; 43:8, 14
structured [1] -
39:20
subject [1] -
32:11
submission [3] -
36:18; 38:3;
42:8
submissions [2] -
40:21; 41:5
submit [3] - 7:6;
39:8; 46:5
submitted [5] -
36:13; 37:19;
40:18; 41:16;
42:14
subpoenas [4] -
33:9, 15
substance [1] -
12:7
substantiate [1] -
36:14
sufficient [1] -
25:13
summarize [2] -
35:5, 13
summarized [2] -
44:4; 47:7
summarizes [1] -
8:4
summary [2] -
43:22, 25
supervise [1] -
23:15
supervised [6] -
22:12; 23:2, 7,
12, 20
supervisor [1] -
26:15
support [2] - 39:1,
8
supported [1] -
44:23
Supreme [7] - 9:3;
24:10, 14, 16,
20; 25:6
surrender [2] -
48:11, 19
surrendered [1] -
46:22
sustaining [1] -
44:24
sworn [1] - 11:16
system [5] - 29:3,
11-12, 18
table [2] - 2:24;
17:20
talent [1] - 38:1
tax [3] - 8:1;
36:10; 42:14
television [1] -
34:19
temporary [1] -
46:21
ten [2] - 26:11;
37:5
terms [11] - 5:16;
10:11, 23;
20:13; 21:3;
26:8; 31:3;
33:24; 46:9;
48:8; 49:5
testify [6] - 32:1,
11, 17, 24;
33:10
testifying [1] -
32:18
THE [287] - 2:3;
3:1, 5, 11, 15,
21-25; 4:1, 6, 9;
5:1, 4-5, 10-11,
14-15, 18-19;
6:7, 16, 22-23;
7:21; 8:3,
14-15, 17,
19-20; 9:7,
10-11; 10:9,
16-17, 21-22;
11:6, 12, 17,
19-22, 24-25;
12:2, 5-6, 8-9,
11-12, 15,
17-18, 20-21;
13:4, 7, 10,
12-13, 17-18,
23-25; 14:1,
3-4, 6-7, 9-10,
12-13, 15-16,
18-21, 25; 15:3,
7-8, 10-11,
13-14, 17-18,
20-21, 23-24;
16:10, 13-14,
17-18, 20-21,
25; 17:1, 5, 8-9,
15, 17, 24-25;
18:8, 11-12,
15-16, 21-22;
19:1, 5-6, 9, 12,
15, 25; 20:1,
5-6, 10-11, 18,
21; 21:2, 6-7,
12, 15, 20, 22;
22:3, 8-9,
17-18, 21-22;
23:1, 10-11,
18-19, 23-24;
24:3, 6-7; 25:4;
26:1, 6-7,
21-22, 24-25;
27:6, 15-16,
22-23; 28:5,
13-14, 16-17,
21-22; 29:1,
5-6, 20-21, 25;
30:1, 10-11,
15-16, 20-21,
24-25; 31:5,
9-10, 14-15,
19-20, 24-25;
32:3, 9-10,
15-16, 20-21;
33:7, 11-12,
20-21; 34:1,
7-8; 35:2; 40:1,
5, 7, 11, 14;
42:22; 43:1, 11,
17, 22, 24-25;
44:2, 5-6, 8-9,
12-13, 16;
46:25; 47:6, 12,
14, 17; 48:5,
15-16, 23-24;
49:5, 7, 9, 11,
13, 15, 24; 50:3,
7, 10, 14
Amanda L. Longmore, RPR, FCRR, Federal Official Court Reporter
Guilty Plea 10/18/25
59
themselves [1] -
2:20
there'd [1] - 33:23
thereafter [1] -
41:9
thereto [2] - 16:3,
8
third [3] - 29:9,
18; 47:9
third-party [1] -
47:9
threat [1] - 47:2
threaten [1] - 18:9
three [4] - 2:7;
25:5; 26:14, 17
three-level [1] -
26:14
throes [1] - 6:17
Thursday [1] -
46:13
today [6] - 4:10;
10:11; 14:14,
23; 28:6; 35:1
together [1] -
35:17
token [2] - 10:17;
20:6
total [6] - 26:17,
19; 38:8; 39:21;
41:9, 12
totally [1] - 23:11
towards [1] -
21:17
transfers [3] -
7:23; 42:19
transmitted [4] -
34:19; 35:25;
42:21
transmitting [1] -
34:18
transport [1] -
39:19
travel [1] - 36:23
treated [1] - 14:7
trial [12] - 15:15;
30:14, 18; 31:6,
17; 32:10, 18;
33:21; 34:4, 12;
35:6
tried [1] - 18:9
truthfully [1] -
13:19
try [2] - 34:15, 17
trying [2] - 2:17;
23:14
twice [2] - 3:14;
22:13
two [11] - 2:7;
24:10, 17;
26:10, 13; 29:9;
Case 1:23-cr-00344-RDB Document 118-1 Filed 09/19/25 Page 59 of 60
34:15, 17;
40:17; 46:10
two-level [3] -
26:10, 13
type [2] - 21:8;
38:6
typically [2] -
38:17, 20
U.S [14] - 2:23;
4:2, 12; 11:4;
16:1; 20:17;
28:1; 30:4; 35:4;
39:2; 43:6; 45:7,
16; 47:8
U.S.C [1] - 36:3
ultimately [5] -
27:3; 28:11;
36:19; 41:18;
48:8
unable [3] - 8:11,
24; 19:19
unanimous [2] -
31:10, 17
under [20] - 5:11,
25; 7:6; 9:2;
10:1, 11, 23;
13:11; 14:10;
17:25; 25:15;
26:19; 29:8, 10;
30:2, 12; 32:4;
49:18, 20
Unit [1] - 21:13
United [14] - 2:3;
6:8; 7:25; 18:19;
24:10, 12-13,
15; 25:6, 16;
35:19; 44:17;
45:3; 49:20
unlawful [2] -
34:16, 23
unless [1] - 32:1
up [7] - 5:3; 11:1;
16:5; 27:11;
34:5; 36:21;
48:10
upheld [2] -
24:14, 16
vaccinated [5] -
2:25; 3:14, 22,
24
vaccination [1] -
2:18
valuable [1] -
18:25
various [8] - 6:18;
37:14, 21;
38:15, 24;
39:14; 42:9, 16
verdict [3] -
31:11, 17; 33:22
versus [9] - 2:4;
9:5; 24:12, 15;
25:6; 43:6;
44:17; 49:19
vertical [1] - 39:18
victim [1] - 6:24
victims [5] - 6:23;
11:8; 26:11;
37:6
view [5] - 17:12,
15; 48:25; 50:1,
8
violate [2] - 23:6,
19
violation [5] - 6:8;
18:18; 20:3;
36:2; 45:3
Virginia [1] - 38:4
visit [1] - 48:16
visiting [1] -
48:13
voice [1] - 5:2
voluntarily [2] -
32:2; 48:19
voluntary [2] -
44:23; 48:11
vote [1] - 19:2
voted [2] - 31:15
waive [5] - 10:24;
29:23; 30:2, 14
waived [1] - 34:4
waiver [5] - 4:22;
5:20, 23; 30:12;
33:23
waives [1] - 6:4
walk [1] - 16:5
Walker [2] - 43:6,
9
warrant [4] - 40:3,
8, 12; 41:24
warrants [1] -
41:25
watch [1] - 31:2
week [1] - 46:11
weeks [2] - 2:7;
46:10
welcome [1] -
50:4
Wells [1] - 41:8
whole [1] - 15:11
wife [2] - 47:10;
48:13
willfully [4] - 7:15;
34:24; 35:25
willing [1] - 48:6
wire [7] - 6:8;
7:23; 18:17;
34:19; 36:1;
42:21; 45:2
wires [2] - 38:4;
Amanda L. Longmore, RPR, FCRR, Federal Official Court Reporter
Guilty Plea 10/18/25
60
42:20
wish [2] - 12:15;
44:6
withdraw [3] -
10:14, 20; 18:2
witness [3] - 32:6
witnesses [5] -
15:14; 31:22;
33:10; 46:2
works [1] - 29:11
worn [1] - 2:11
write [1] - 14:5
writings [1] - 36:2
written [3] - 15:2,
5; 45:6
wrongfully [1] -
6:20
Yazee [1] - 41:4
year [11] - 5:7;
11:22; 12:24;
27:11; 28:18,
23; 29:7, 13, 15
years [18] - 10:7,
13, 19; 22:11,
15; 24:13; 25:5;
27:4, 14, 17;
29:9, 16; 48:9
years' [1] - 27:18
yourself [1] -
23:16
§ [4] - 6:9; 18:19;
25:16; 45:4
§§ [1] - 36:3
Case 1:23-cr-00344-RDB Document 118-1 Filed 09/19/25 Page 60 of 60File and source
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