Exhibit 122 — USA v. McCabe (Dkt. 91.129)

Summary

Exhibit 122 (Document 91-129), marked Government Exhibit, is Trial Stipulations in United States of America v. Dustin Sean McCabe, Case No. 24-80103-CR-CANNON, Southern District of Florida. The parties stipulate to facts the jury must accept as proved beyond a reasonable doubt. First, the IRS Form Schedule C for tax year 2019, which the Defendant submitted to Celtic Bank with a Paycheck Protection Program application in May 2020 and which is admitted as Exhibit GX121, was never filed with the IRS. Second, the IRS Form 1120 for tax year 2020, which the Defendant submitted to Cross River Bank with a PPP application in February 2021 and which is admitted as Exhibit GX93, was never filed with the IRS. The signature block names Hayden P. O'Byrne, Zachary A. Keller, Terrence O'Sullivan and the Defendant.

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Case 9:24-cr-80103-AMC Document 91-129 Entered on FLSD Docket 03/10/2025 Page 1 of 2

GOVERNMENT
EXHIBIT

UNITED STATES DISTRICT COURT BARE 24-CR-B0103-AMC
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, stipulate and agree to the following facts, which the jury must accept as
having been proved beyond a reasonable doubt:

1; The Internal Revenue Service (“IRS”) Form Schedule C, “Statement of Profit or
Loss From Business” tax document for the tax year 2019, which the Defendant submitted to Celtic
Bank in connection with a Paycheck Protection Program (“PPP”) application in May 2020 and

which is marked and admitted as the United States’ Exhibit GX121, was never filed with the IRS.

[Remainder of Page Intentionally Left Blank]
Case 9:24-cr-80103-AMC Document 91-129 Entered on FLSD Docket 03/10/2025 Page 2 of 2

2. The IRS Form 1120, “U.S. Corporation Income Tax Return” tax document for the
tax year 2020, which the Defendant submitted to Cross River Bank in connection with a PPP
application in February 2021 and which is marked and admitted as the United States’ Exhibit

GX93, was never filed with the IRS.

HAYDEN P. O’BYRNE
UNITED STATES ATTORNEY

Date:

ZACHARY A. KELLER
ASSISTANT UNITED ES ATTORNEY

Date: ganas By: 0 ‘gat KUED |

TERRENCE O’SULLIVAN
ATTORNEY FOR DEFENDANT

C
Date: 2 Fe 202d 2. : [Mote

DUSTIN SEAN McCABE
DEFENDANT


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