Plea Agreement as to Felicia Jackson Stanley — USA v. Stanley et al. (Dkt. 24, N.D. Fla.)

Record facts

U.S. District Court for the Northern District of Florida · No. 4:22-cr-00032-MW-MAF · Doc. 24 · 2022-07-29 · Docket on CourtListener

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Case 4:22-cr-00032-MW-MAF Document 24 _ Filed 07/29/22 Page1of7

IN THE UNITED STATES DISTRICT COURT
FOR THE NORTHERN DISTRICT OF FLORIDA
GAINESVILLE DIVISION

UNITED STATES OF AMERICA

v. CASE NO. 4:22-cr-32-MW/MAF
FELICIA TIFFANY JACKSON-STANLEY
/
PLEA AGREEMENT

1. PARTIES TO AGREEMENT

This agreement is entered into by and between Felicia Tiffany Jackson-
Stanley as Defendant, Robert Alex Morris as attorney for Defendant, and the United
States Attorney for the Northern District of Florida. This agreement specifically
excludes and does not bind any other state or federal agency, including other United
States Attorneys and the Internal Revenue Service, from asserting any civil,
criminal, or administrative claim against Defendant.

2. TERMS

The parties agree to the following terms:

a. Defendant will plead guilty to Count One (Wire Fraud Conspiracy),
Count Two (Money Laundering Conspiracy), and Count Three (False Statements)
of the Information. As to Count One, Defendant faces a maximum term of twenty
years’ imprisonment, three years of supervised release, a $250,000 fine, and a $100

We ymaree

Cuerk, Unirep States District Co}
NoRTHERN DISTRICT OF FLORIDA
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special monetary assessment. As to Count Two, Defendant faces a maximum term
of ten years’ imprisonment, three years of supervised release, a $250,000 fine, and
a $100 special monetary assessment. As to Count Three, Defendant faces a
maximum term of five years’ imprisonment, one year of supervised release, a
$250,000 fine, and a $100 special monetary assessment. Defendant agrees to pay the
special monetary assessment(s) on or before the date of sentencing.

If Defendant is unable to pay the special assessment prior to sentencing due
to indigence, Defendant agrees to participate in the Inmate Financial Responsibility
Program.

The maximum sentence to which Defendant is subject includes the forfeiture
of all forfeitable assets. The Defendant specifically agrees to the forfeiture of the
following assets:'

l. Real property located and situated in Leon County, Florida, located at

1660 Kay Avenue, Units 1,2,3,4,5,6,7,and 8, Tallahassee, FL 32301,
and all areas designated as common elements of Greenside
Condominiums, further described in Leon County Official Records
Book 5470 and Page 79, and known to the Leon County Property
Appraiser as Parcel Identification #s 3108360000010, 3108360000020,

3108360000030, 3108360000040, 3108360000050, 3108360000060,
3108360000070, 3108360000080, respectively.

' The Government has agreed that it will not proceed with forfeiture of the assets listed herein if
the Defendants pay restitution described herein in full prior to sentencing in this case.

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b.

Real property located and situated in Leon County, Florida:

Lot 10, Block C, Tallahassee Ranch Club, according to the plat thereof,
recorded in Plat Book 18, Page(s) | through 35, of the inclusive, Public
Records of Leon County, Florida, and further described in Leon County
Official Records Book 5496 and Page 1308, and known to the Leon
County Property Appraiser as Parcel Identification # 332525 C0100.

Real property located and situated in Leon County, Florida, located at
3770 Laurel Trace Way, Tallahassee, FL 32303, described as:

Lot 6, Block D of Laurel Trace, According to the Plat thereof as
Recorded in Plat Book 16, Page 75, of The Public Records of Leon
County, Florida, and further described in Leon County Official Records
Book 5510 and Page 39, and known to the Leon County Property
Appraiser as Parcel Identification #2 10929D0060.

The Coinbase account with user identification number ending in
9b775ae, held in the name of WILBERT STANLEY and/or associated
with email address yepwekan@gmail.com.

The Coinbase account with user identification number ending in
8d710141, held in the name of FELICIA STANLEY and/or associated
with email address liciapooh01@hotmail.com.

The Robinhood account ending in 2819, held in the name of FELICIA
STANLEY.

The Robinhood account ending in 1939, held in the name of
WILBERT STANLEY.

The TD Ameritrade account ending in 1466, held in the name of
FELICIA JACKSON-STANLEY.

By voluntarily pleading guilty to the charge(s) in the Information,

Defendant, as to the count(s) pled herein, knowingly waives and gives up

constitutional rights which attend a defendant on trial in a criminal case. These

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constitutional rights include: the right to plead not guilty; the right to have a jury or
judge determine guilt on the evidence presented; the right to compel the government
to prove guilt beyond a reasonable doubt; the right to confront and cross-examine
witnesses; the right not to be compelled to incriminate oneself; the right to testify;
the right to present evidence; and the right to compel the attendance of witnesses.

cs. Defendant is pleading guilty because Defendant is in fact guilty of the
charges alleged in Counts One through Three of the Information. In pleading guilty,
Defendant acknowledges that were this case to go to trial, the government would
present evidence to support the charge(s) beyond a reasonable doubt.

d. Upon the District Court's adjudication of guilt of Defendant for the
charged crime(s), the United States Attorney, Northern District of Florida, will not
file any further criminal charges against Defendant arising out of the same
transactions or occurrences to which Defendant has pled. Defendant agrees that
substantial evidence exists to support the charge(s), as indicated in the agreed-upon
statement of facts incorporated by reference into this plea agreement.

2; Nothing in this agreement shall protect Defendant in any way from
prosecution for any offense committed after the date of this agreement.

f. If Defendant is not a citizen of the United States, Defendant

understands that this conviction may adversely affect Defendant’s immigration

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status, and Defendant may be removed from the United States, denied citizenship in
the United States, and denied admission to the United States in the future.

g. The parties agree that the sentence to be imposed is left solely to the
discretion of the District Court, which is required to consult the United States
Sentencing Guidelines and take them into account when sentencing Defendant. The
parties further understand and agree that the District Court’s discretion in imposing
sentence is limited only by the statutory maximum sentence and any mandatory
minimum sentence prescribed by statute for the offense(s).

h. Both parties reserve the right to advise the District Court and other
authorities of their versions of the circumstances surrounding the offense(s)
committed by Defendant. The United States Attorney further reserves the right to
correct any misstatements by Defendant or Defendant’s attorney and to present
evidence and make arguments pertaining to the application of the sentencing
guidelines and the considerations set forth in Title 18, United States Code, Section
3553(a), including sentencing recommendations, and whether departure or variance
upward or downward is appropriate.

3. SENTENCING
a. Defendant understands that any prediction of the sentence that may be

imposed is not a guarantee or binding promise. Due to the variety and complexity of

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issues that may arise at sentencing, the sentence may not be subject to accurate
prediction.

b. The parties understand and agree that either party may offer additional
evidence relevant to sentencing issues. However, the Court is not limited to
consideration of the facts and events provided by the parties. Adverse rulings or a
sentence greater than anticipated shall not be grounds for withdrawal of Defendant’s
plea.

c The parties reserve the right to appeal any sentence imposed.

4. VICTIM RESTITUTION
Defendant agrees to make full restitution to the victim, the United States Small
Business Administration, in the amount of $2,802,690.76.* Defendant agrees that
the amount of restitution may include losses resulting from related conduct for which
Defendant was not convicted, if the loss flowed directly from the relevant conduct

of which Defendant was a part.

? Calculated using the figures contained in the charts listed in the Statement of Facts for this case
as follows: (the sum of all loan/grant proceeds issued in the name of the defendants or their
alleged business entities) + (1/3 of the sum of all loan/grant proceeds issued in the names of
third-parties or their alleged business entities) [which was the average “fee” charged by the
defendants to the third-parties whose names and PII were used to fraudulently obtain SBA
loan/grant proceeds].

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CONCLUSION

In every case in the Northern District of Florida in which the parties enter a
Plea Agreement, the Court requires the parties to enter a sealed Supplement to Plea
Agreement indicating whether or not Defendant agrees to cooperate with the United
States Attorney. The parties agree to the Supplement to Plea Agreement entered in
this case.

Defendant enters this agreement knowingly, voluntarily, and upon advice of

counsel.
OO fos
Robert Alex Morris Justin M. Keer © ~
Attorney for Defendant Florida Bar No. 021034
Assistant United States Attorney
a Lf: te Northern District of Florida
. 111 North Adams Street, 4" Floor
WA Tallahassee, FL 32301
850-942-8430
elicia Tiffany Jackson-Stanley Justin. Keen@usdoj.gov
Defendant
19-4 #2 4/29/2022
Date ' Date |

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