Attachment A (Stipulation) — USA v. McCabe (Dkt. 60.1)

Record facts

U.S. District Court for the Southern District of Florida · No. 9:24-cr-80103-AMC · Doc. 60-1 · 2025-02-21 · Docket on CourtListener

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UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF FLORIDA 
CASE NO. 24-80103-CR-CANNON 
UNITED STATES OF AMERICA  
v. 
DUSTIN SEAN McCABE,  
 
Defendant. 
________________________________/ 
TRIAL STIPULATIONS 
COMES NOW, THE UNITED STATES OF AMERICA, by and through the undersigned 
Assistant United States Attorney, and the Defendant, DUSTIN SEAN McCABE, personally and 
through his attorney, and stipulate and agree to the following facts, which the jury must accept as 
having been proved beyond a reasonable doubt: 
1.
The Defendant, DUSTIN SEAN McCABE, was the owner and captain of the M/V
SOUTHERN COMFORT on March 28 and 29, 2020. 
2.
The disbursement of Paycheck Protection Program loan number 5224667409 from
Celtic Bank, identified in the Indictment as “Bank Processor 1,” in the approximate amount of 
$18,750, by Automated Clearing House (“ACH”) transfer to Knoxville TVA Employees Credit 
Union, identified in the Indictment as Credit Union 1, as well as the attending loan forgiveness 
application, were wire communications transmitted in interstate commerce. Among other things, 
Celtic Bank is headquartered in Utah, and Knoxville TVA Employees Credit Union is 
headquartered in Tennessee. 
3.
The disbursement of Paycheck Protection Program loan number 4387648301 from
Cross River Bank, identified in the Indictment as “Bank Processor 2,” in the approximate amount 
Attachment A
Case 9:24-cr-80103-AMC   Document 60-1   Entered on FLSD Docket 02/21/2025   Page 1 of 2

 
 
2 
of $20,385, by ACH transfer to Knoxville TVA Employees Credit Union, identified in the 
Indictment as Credit Union 1, as well as the attending loan forgiveness application, were wire 
communications transmitted in interstate commerce. Among other things, Cross River Bank is 
headquartered in New Jersey, and Knoxville TVA Employees Credit Union is headquartered in 
Tennessee. 
 
 
 
 
 
 
      HAYDEN P. O’BYRNE 
 
 
 
 
 
      UNITED STATES ATTORNEY 
 
 
 
Date:                       
 
By:   
                
 
 
 
 
 
                                    
 
 
 
 
 
      ZACHARY A. KELLER 
 
 
 
 
 
      ASSISTANT UNITED STATES ATTORNEY 
 
 
 
Date:                       
 
By:                      
 
 
 
 
 
                                    
 
 
 
 
 
      TERRENCE O’SULLIVAN 
 
 
 
 
 
      ATTORNEY FOR DEFENDANT 
 
 
 
Date:                        
 
By:                      
 
 
 
 
 
                
 
 
 
 
 
      DUSTIN SEAN McCABE 
 
 
 
 
 
      DEFENDANT 
Case 9:24-cr-80103-AMC   Document 60-1   Entered on FLSD Docket 02/21/2025   Page 2 of 2

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