Docket 1:24-cr-00017-RSB-PMS-2 — Doc 390-0

Record facts

U.S. District Court for the Western District of Virginia · No. 1:24-cr-00017-RSB-PMS · Doc. 390 · 2024-09-26 · Docket on CourtListener

Full text

IN THE UNITED STATES DISTRICT COURT
FOR THE WESTERN DISTRICT OF VIRGINIA
ABINGDON DIYISION
UNITED STATES OF AMERICA
v.
CRYSTAL SAMANTHA SHAW
Case No. 1224-CR-17
PLEA AGREEMENT
I have agreed to enter into a plea agreement with the United States of America,
pursuant to Rule 11 of the Federal Rules of Criminal Procedure. The terms and conditions
of this agreement are as follows:
A. CHARGE($ TO WHICH I AM PLEADING GUILTY AND WAIVER OF
RIGHTS
1. The Charses and Potential Punishment
My attorney has informed me of the nature of the charge(s) and the elements of the
charge(s) that must be proved by the United States beyond a reasonable doubt before I
could be found guilty as charged.
I will enter a plea of guilty to Count I of the Indictment.
Count I charges me with conspiring to defraud the United States and commit an
offense against the United States, to wit: filing fraudulent claims for pandemic
unemployment benefits as authorized by, and administered through federal law, in
violation of Title 18, United States Code, $ 1040(a), such benefits being authorized,paid,
and disbursed in connection with the Coronavirus Disease (COVID-19) pandemic, an
emergency declaration under $ 501 of the Robert T. Stafford Disaster Relief and
Emergency Assistance Act (42 U.S.C. $ 5191), by providing personal identifring
information for the purpose of filing fraudulent claims for pandemic unemployment
benefits in order to receive funds to which they were not entitled, in violation of Title 18,
United States Code S 371. The maximum statutory penalty is a fine of $250,000 and/or
imprisonment for a term of five years, plus a term of supervised release of three years.
D efe ndant' s I niti ctl 
s :e&
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I understand restitution may be ordered, my assets may be subject to forfeiture, and
fees may be imposed to pay for incarceration, supervised release, and costs of prosecution.
In addition, a $100 special assessment, pursuant to 18 U.S.C. $ 3013, will be imposed per
felony count of conviction. I further understand my supervised release may be revoked if I
violate its terms and conditions. I understand a violation of supervised release increases the
possible period of incarceration.
I am pleading guilty as described above because I am in fact guilty and because I
believe it is in my best interest to do so and not because of any threats or promises not set
forth in this agreement. There has been no promise made whatsoever by anyone as to what
the final disposition of this matter will be.
I agree and stipulate I committed the other crimes charged in the Indictment.
Specifically, I did commit fraud in connection with emergency benefits and conspired to
commit mail fraud. Accordingly, pursuant to U.S.S.G. $ lBl .2, the guidelines should be
calculated as if I had been convicted of those offenses.
If I comply with my obligations under the plea agreement, the United States will
move, at sentencing, that I be dismissed as a defendant in any remaining count(s). I
stipulate and agree the United States had probable cause to bring all the counts in the
Indictment which are being dismissed under this agreement, these charges were not
frivolous, vexatious or in bad faith, and I am not a "prevailing party" with regard to these
charges. I further waive any claim for attorney's fees and other litigation expenses arising
out of the investigation or prosecution of this matter.
2. Waiver of Constitutional Biehts Upon a Plea of Guiltv
I acknowledge I have had all of my rights explained to me and I expressly recognize
I have the following constitutional rights and, by voluntarily pleading guilty, I knowingly
waive and give up these valuable constitutional rights:
a. The right to plead not guilty and persist in that plea;
b. The right to a speedy and public jury trial;
c. The right to assistance of counsel at that trial and in any subsequent appeal;
d. The right to remain silent attrial;
e. The right to testiff attrial
f. The right to confront and cross-examine witnesses called by the government;
g. The right to present evidence and witnesses in my own behalf;
h. The right to compulsory process of the court;
D efen cl a nt' s I niti al s :CS-
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i. The right to compel the attendance of witnesses at trial;
j. The right to be presumed innocent;
k. The right to a unanimous guilty verdict; and
l. The right to appeal a guilty verdict.
B. SENTENCING PROVISIONS
L. General Matters
I understand the determination of what sentence should be imposed, within the
confines of any applicable statutory minimums andmaximums, is in the sole discretion of
the Court subject to its consideration of the United States Sentencing Guidelines
("guidelines" or "LJ.S.S.G") and the factors set forth at 18 U.S.C. $ 3553(a). I understand
I will have an opportunity to review a copy of my presentence report in advance of my
sentencing hearing and may file objections, as appropriate. I will have an opportunity at
my sentencing hearing to present evidence, bring witnesses, cross-examine any witnesses
the government calls to testify, and argue to the Court what an appropriate sentence should
be within the confines of the terms of this agreement.
I understand I will not be eligible for parole during any term of imprisonment
imposed. I understand the Court is not bound by any recommendation or stipulation
contained in this agreement and may sentence me up to the statutory maximum. I
understand I will not be allowed to withdraw my plea of guilty if the Court disregards the
stipulations andlor recommendations set forth in the plea agreement.
I understand if the sentence is more severe than I expected, I will have no right to
withdraw my plea. I have discussed sentencing issues with my attorney andrealize there is
a substantial likelihood I will be incarcerated.
2. SentencinsGuidelines
I stipulate and agree that all matters pertaining to any of the counts of the charging
document(s), including any dismissed counts, are relevant conduct for purposes of
sentencing.
The parties agree the 2023 edition of the United States Sentencing Guidelines
Manual applies to any guidelines calculation made pertaining to my offense(s). I stipulate
that the following guideline section(s) are applicable to my conduct:
D efendant' s I nitial s : I
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2Bt.t/a\Q
2Br.rb
Loss amount: $297,157
2Bt.r(b)(rz
the offense involved conduct described in
18 U.S.C. $ 1040 (if the resulting offense
level is less than level 12, increase to
The United States stipulates that the guideline section(s) set forth in this section
should apply to my conduct.
I understand other guideline sections may be applicable to my case and ttre United
States and I will be free to argue whether these sections should or should not apply,
including, but not limited to, whether an adjustment pursuant to USSG $ 381.1 should
apply to my conduct due to my role in the offense, to the extent the arguments are not
inconsistent with the stipulations, recofirmendations and terms set forth in this plea
agreement.
I agree to accept responsibility for my conduct. If I comply with my obligations
under this plea agreement and accept responsibility for my conduct, the United States will
recommend the Court grant me a two-level reduction in my offense level, pursuant to
U.S.S.G. $ 3E1.1(a) and, if applicable, at sentencing, will move that I receive a oneJevel
reduction in my offense level, pursuant to U.S.S.G. $ 3E1.1(b), for pulposes of any
guidelines calculation. However, I stipulate that if I fail to accept responsibility for my
conduct or fail to comply with any provision of this plea agreement, I should not receive
credit for acceptance of responsibility.
3. Monetary Oblieations
a. Special Assessments, Fines and Restitution
I understand persons convicted of crimes are required to pay a mandatory
assessment of $100.00 per felony count of conviction. I agree I will submit to the U.S.
Clerk's Office, a certified check, money order, or attorney's trust check, made payable to
the "Clerk, U.S. District Court" for the total amount due for mandatory assessments prior
to entering my plea of guilty.
D efendant's Initictls : (!
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Guideline Section(s)
f)escriotion(s)
6
Base Offense Level
+t2
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I agree to pay restitution to the.virginiaEmployment commission in the amount of
$297'157' which represents pandemic ,ri.*ptoyil"rii benefits paid in connection with
applications submitted in my n*. or the nrrn., orott lrc with whom I conspired to submit
fraudulent applications for benefits to which either I or other persons were not entitled. In
addition, I agree to pay any restituti":_l..gtt;Jtylrry, llcluding, bur not limited to,
amounts due pursuant.to 18 usc $$ 2259, ieaz, uiui 3663A.I ,iderstand and agree a
requirementrpay restitution ror ailrme-above-stat.a *utto, will be imposed upon me
as part of any final judgment in this matter. au resiitution payments should be made
payable and submitted to the "clerlg u.S. District court.,,
I further ugt:t to make good faith efforts toward payment of all mandatory
assessments, restitution and fines, with whatever means I !;; at my diqposat. I agree
failure to do so will constitute a violation of this ug..*.rt. I will execute any documents
necessary to release the funds I have in.any ,.porIto.y, bank, inu.ri*.ri lrrr., financial
institution, or any other location in order to il; ;;ial or total payment toward the
mandatory assessments, restitution and nn.r impor.din rry.ur..
I fully understand restitution and.forfeityre_are separate financial obligations which
may be imposed upon a criminal defendant. I further uriderstand there is a process within
the Department of lultige whereby, in certain circumstances, forfeited 'funds may be
applied to restitution obligations. I Lnderstand no one r,u, .uo. any promises to me that
such a process will result in a decrease in my ,.Jd;; ;brigations in this case.
I understand *l agree, pursuant to rg u.s.c. $$ 3613 and 3664(m), whatever
monetary penalties are imposed by the court will be (iiiue i**.Jiut.r, ilo subject to
immediate enforcement by the united states as providifor by 1g u.s.c. $ 3613, and (ii)
submitted to the Treasury offset Program so that any federal payment"or transfer of
retumed property to the defendant -uy U. offset ana apptied to federal debts but will not
affect the periodic payment schedule. i furth., understand if the court t,"p;;;, a schedule
of payments, that schedule is only a minimum schedule of payments and not the only
method, nor a limitation on the methods, available to the United States to enforce the
judgment.
I agree to grant the United States a wage assignment, liquidate assets, or complete
any other tasks which will result in immediate payment in full, or payment in the shortest
time in which full payment can be reasonably rnade as required undir-l8 U.S.C. $ 3572(d).
I expressly authorize the United States Attorney's Office to obtain a credit report on
Defendant's Initials : 5
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me in order to evaluate my ability to satisfy any financial obligation imposed by the Court.
I agree the following provisions, or words of similar effect, should be included as
conditions of probation and/or supervised release: (1) "The defendant shall notiff the
Financial Litigation Unit, United States Attomey's Office, in writing, of any interest in
property obtained, directly or indirectly, including afly interest obtained under any other
name, or entity, including a trust, partnership or corporation after the execution of this
agreement until all fines, restitution, money judgments and monetary assessments are paid
in full" afi (2) "The Defendant shall noti$ the Financial Litigation Unit, United States
Attorney's Office, in writing, at least 30 days prior to transferring any interest in property
owned directly or indirectly by Defendant, including any interest held or owned under any
other name or entity, including trusts, partnership andlor corporations until all fines,
restitution, money judgments and monetary assessments are paid in full."
The parties will also jointly recommend that as a condition of probation or
supervised release, Defendant will notiff the Financial Litigation Unit, United States
Attorney's Office, before Defendant transfers any interest in property owned directly or
indirectly by Defendant, including any interest held or owned under any other name or
enttty, includingtrusts, partnership and/or coqporations. See 18 U.S.C. $ 3664(k), (n).
Regardless of whether or not the Court specifically directs participation or imposes
a schedule of payments, I agree to fully participate in inmate employment under any
available or recommended programs operated by the Bureau of Prisons.
I agree any payments made by me shall be applied fully to the non-joint and several
portion of my outstanding restitution balance until the non-joint and several portion of
restitution is paid in full, unless the Court determines that to do so would cause a hardship
to a victim of the offense(s).
b. Duty to Make Financial Disclosures
I understand in this case there is a possibility substantial fines and/or restitution may
be imposed. In order to assist the United States as to any recommendation and in any
necessary collection of those sums, I agree, if requested by the United States, to provide a
complete and truthful financial statement to the United States Attorney's Office, within 30
days of the request or 3 days prior to sentencing, whichever is earlier, detailing all income,
expenditures, assets, liabilities, gifts and conveyances by myself, my spouse and my
dependent children and any corporation, partnership or other entity in which I hold or have
held an interest, for the period starting on January l't ofthe year prior to the year my offense
Defendant's Initials: C 5
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began and continuing tluough the date of the statement. This financial statement shall be
submitted in a form acceptable to the United States Attomey's office.
From the time of the signing of this agreement or the date I sign the financial
statement, whichever is earlier, I agree not to convey anything of value to any person
without the authorization of the United States Attorney's Office.
c. Understandine of Collection Matters
I understand:
1. as part ofthe judgment in this case I will be ordered to pay one or more monetary
obligations;
2. payment should be made as ordered by the Court;
3. I must mail payments, by cashier's check or money order, payable to the "Clerk,
U.S. District Court" to: 210 Franklin Road, S.W., Suite 540, Roanoke, Virginia
240L1; and include my name and court number on the check or money order;
4. interest (unless waived by the Court) and penalties must be imposed for late or
missed payments;
5. the United States may file liens on my real and personal property that will remain
in place until monetary obligations are paid in full, or until liens expire (the later
of20 years from date ofsentencing or release from incarceration);
6. if I retain counsel to represent me regarding the United States' efforts to collect
any of my monetary obligations, I will immediately notiff the United States
Attorney's Office, ATTN: Financial Litigation Unit, P.O. Box 1709, Roanoke,
Virginia 24008-t709, in writing, of the fact of my legal representation; and
7, I, or my attomey if an attorney will represent me regarding collection of
monetary obligations, can contact the U.S. Attorney's Office's Financial
Litigation Unit at 540/857-2259.
C. ADDITIONAL MATTERS
1. Waiver of Rieht to Appeal
Knowing that I have a right of direct appeal of my sentence under 18 U.S.C.
$ 37a2@) and the grounds listed therein, I expressly waive the right to appeal my sentence
on those grounds or on any ground. In addition, I hereby waive my right of appeal as to
any and all other issues in this matter and agree I will not file a notice of appeal. I am
knowingly and voluntarily waiving any right to appeal. By signing this agreement, I am
Deferulant's Initiuls: f S
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explicitly and irrevocably directing my attomey not to file a notice of appeal.
Notwithstonding any other language to the contrary, I am not woiving my right to appeol
or to have my attorney tile u notice of appeal, as to any issue which cannot be waived, by
law. I understand the United States expressly reserves all of its rights to appeal. I agree
and understand if I lile any court document (except for an appeal based on an issue
that cannot be waived, by law, or a collateral attack based on ineffective assistance of
counsel) seeking to disturbo in any way, any order imposed in my case such action
shall constitute a failure to comply with a provision of this agreement.
2. Waiver of Risht to Collaterally Attack
I waive any right I may have to collaterally allack, in any future proceeding, any
order issued in this matter, urless such attack is based on ineffective assistance of counsel,
and agree I will not file any document which seeks to disturb any such order, unless such
filing is based on ineffective assistance of counsel. I agree and understand that if I file
any court document (except for an appeal based on an issue not otherwise waived in
this agreement; an appeal based on an issue that cannot be waived, by law; or a
collateral attack based on ineffective assistance of counsel) seeking to disturbn in any
way, any order imposed in my case, such action shall constitute a failure to comply
with a provision of this agreement.
3. Information Access Waiver
I knowingly and voluntarily agree to waive all rights, whether asserted directly or
by a representative, to request or.receive from any department or agency of the United
States any records pertaining to the investigation or prosecution of this case, including
without limitation any records that may be sought under the Freedom of Information Act,
5 U.S.C. $552, or the Privacy Act of 1974,5 U.S.C. 9552a.
4. Waiver of Witness Fee
I agree to waive all rights, claims or interest in any witness fee I may be eligible to
receive pursuant to 28 U.S.C. $ 1821, for my appearance at arry Grand Jury, witness
conference or court proceeding.
5. Abandonment of Seized Items
By signing this plea agreement, I hereby abandon my interest in, and consent to the
official use, destruction or other disposition of each item obtained by any law enforcement
Defendant's Inifials: ( 
<
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agency during the course of the investigation, unless such item is specifically provided for
in another provision of this plea agreement. I further waive any and all notice of any
proceeding to implement the official use, destruction, abandonment, or other disposition of
such items.
6. Deportation
I understand if I am not a citizen of the United States, or if I am a naturalizedcitizen,
pleading guilty may have consequences with respect to my immigration status including,
but not limited to, deportation from the United States, denial of United States citizenship,
denial of admission to the United States in the future, or denaturalization. I expressly
recognize under federal law, conviction for a broad range of crimes can lead to adverse
immigration consequences including, but not limited to, automatic removal from the
United States, and that no one, including my attorney or the Court, can predict with
certainty the effect of a conviction on my immigration status. I am not relying on any
promise or belief about the immigration consequences of pleading guilty. I want to plead
guilty regardless of any potential immigration consequences.
7. Admissibility of Statements
I agree if I fail to plead guilty in accordance with this agreement or withdraw my
plea(s) of guilty any statements I make that may be inadmissible in the absence of this
provision, including this plea agreement, and my admission of guilt, during or in
preparation for any guilty plea hearing, sentencing hearing, or other hearing and any
statements I make or have made to law enforcement agents, in any setting (including during
any proffer), may be used against me in this or any other proceeding. I knowingly waive
any right I may have under the Constitution, any statute, rule or other source of law to have
such statements, or evidence derived from such statements, suppressed or excluded from
being admitted into evidence and stipulate that such statements can be admitted into
evidence.
8. AdditionalOblieations
I agree not to commit any of the following acts:
o attempt to withdraw my guilty plea;
o deny I committed any crime to which I have pled guilty;
o make or adopt any arguments or objections to the presentence report that are
inconsistent with this plea agreement;
Defendant's Initials: &
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o obstruct justice;
o fail to comply with any provision of this plea agreement;
o commit any other crime;
o make a false statement; or
o fail to enter my plea of guilty when scheduled to do so, unless a continuance
is agreed to by the United States Attorney's Office and granted by the Court.
D. REMEDIES AVAILABLE TO THE UNITED STATES
I hereby stipulate and agree that the United States Attorney's Office may, at its
election, pursue imy or all of the following remedies if I fail to comply with any provision
of this agreement or if the Court rejects this plea agreement: (a) declare this plea agreement
void; (b) refuse to dismiss any charges; (c) reinstate any charges dismissed or as to which
I pled guilty to a lesser included offense; (d) file new charges conceming the matters
involved in the instant investigation; I refuse to abide by any provision, stipulations, and/or
recommendations contained in this plea agreement; or (f) take any other action provided
for under this agreement or by statute, regulation or court rule. I hereby waive any double
jeopardy, speedy trial, undue delay, or statute of limitations defense I may have as to any
reinstated, newly-filed, or non-dismissed charges described in this paragraph. I agree the
provisions of this section are contractual obligations between the United States and me that
are severable from the plea agreement and survive any Court's rejection of the plea
agreement.
In addition, I agree if for any reason, my conviction is set aside, or I fail to comply
with any obligation under the plea agreement, the United States may file, by indictment or
informatior, ffiy charges against me which were filed and/or could have been filed
conceming the matters involved in the instant investigation. I hereby waive my right under
Federal Rule of Criminal Procedure 7 tobe proceeded against by indictment and consent
to the filing of an information against me conceming any such charges. I also hereby waive
any statute of limitations defense as to any such charges.
The remedies set forth above are cumulative andnotmutually exclusive. The United
States' election of any of these remedies, other than declaring this plea agreement void,
does not, in any way, terminate my obligation to comply with the terms of the plea
agreement. The use of "if in this section does not mean "if, and only if."
E. GENERAL PROVISIONS
1. Limitation of Aereement
Defendant's Initials: C ,f
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This agreement only binds the United States Attorney's Offrce for the Western
District of Virginia. It does not bind any state or local prosecutor, other United States
Attorney's Office or other office or agency of the United States Government, including,
but not limited to, the Tax Division of the United States Department of Justice or the
Intemal Revenue Service of the United States Department of the Treasury. These
individuals and agencies remain free to prosecute me for any offense(s) committed within
their respective j urisdictions.
2. Effect of My Sienature
I understand my signature on this agreement constitutes a binding offer by me to
enter into this agreement. I understand the United States has not accepted my offer until it
signs the agreement.
I confirm that while I considered signing this Agreement, and at the time I signed
it, I was not under the influence of any alcohol, drug, or medicine that would impair my
ability to understand the agreement.
3. Effective Representation
I have discussed the terms of the foregoing plea agreement and all matters pertaining
to the charges against me with my attorney and am fully satisfied with my attorney and my
attorney's advice. At this time, I have no dissatisfaction or complaint with my attorney's
representation. I agree to make known to the Court no later than at the time of sentencing
any dissatisfaction or complaint I may have with my attorney's representation.
4. Misconduct
If I have any information conceming any conduct of any government attorney,
agent, employee, or contractor which could be construed as misconduct or an ethical, civil,
or criminal violation, I agree to make such conduct known to the United States Attorney's
Office and the Court, in writing, as soon as possible, but no later than my sentencing
hearing.
5. f inal Matters
I understand athorough presentence investigation will be conducted and sentencing
recommendations independent of the United States Attomey's Office will be made by the
Defendant's Initials: (-L
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presentence preparer, which the Court may adopt or take into consideration. I understand
any calculation regarding the guidelines by the United States Attorney's Office or by my
attorney is speculative and is not binding upon the Court, the Probation Office or the United
States Attomey's Office. No guarantee has been made by anyone regarding the effect of
the guidelines on my case.
I understand the prosecution will be free to allocute or describe the nature of this
offense and the evidence in this case and make any recommendations not prohibited by
this agreement.
I understand the United States retains the right, notwithstanding any provision in
this plea agreement, to inform the Probation Office and the Court of all relevant facts, to
address the Court with respect to the nature and seriousness of the offense(s), to respond
to any questions raised by the Court, to correct any inaccuracies or inadequacies in the
presentence report and to respond to any statements made to the Court by or on behalf of
the defendant.
I willingly stipulate there is a sufficient factual basis to support each and every
material factual allegation contained within the charging document(s) to which I am
pleading guilty.
I understand this agreement does not apply to any crimes or charges not addressed
in this agreement. I understand if I should testiff falsely in this or in a related proceeding I
may be prosecuted for perjury and statements I may have given authorities pursuant to this
agreement may be used against me in such a proceeding.
I understand my attorney will be free to argue any mitigating factors on my behalf;
to the extent they are not inconsistent with the terms of this agreement. I understand I will
have an opportunity to personally address the Court prior to sentence being imposed.
This writing and any associated addenda filed with the Court set forth the entire
understanding between the parties and constitute the complete plea agreement between the
United States Attomey for the Western District of Virginia and me, and no other additional
terms or agreements shall be entered except and unless those other terms or agreements are
in writing and signed by the parties. This plea agreement supersedes all prior
understandings, promises, agreements, or conditions, if any, between the United States and
me.
I have consulted with my attorney and fully understand all my rights. I have read
-- ;-'
Defentlant's Initials: a \
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this plea agreement and carefully reviewed every part of it with my attorney. I understand
this agreement and I voluntarily agree to it. I have not been coerced, threatened, or
promised anything other than the terms of this plea agreement, described above, in
exchange for my plea of guilty. Being aware of all of the possible consequences of my
plea, I have independently decided to enter this plea of my own free will, and am afflrrming
that agreement on this date and by my signature_below.
CRYST
SAMANTHA SHAW, Defendant
I have fully explained all rights available to my client with respect to the offenses listed in
the pending charging document(s). I have carefully reviewed every part of this plea
agreement and any associated addenda with my client. To my knowledge, my client's
decision to enter into this agreement is an informed and voluntary one.
If I will continue to represent my client regarding the United States' efforts to collect
any monetary obligations, I will notify the United States Attorney's Office, ATTN:
Financial Litigation Unit, P.O. Box 1709, Roanoke, Virginia 24008-1709, in writing, of
the fact of my continued legal representation within 10 days of the entry ofjudgment in
this case.
q"Zo-2 1
Date: I
Date:
MARSHA ANN ARNURIUS, Esq.
Counsel for Defendant
M. SUZANNE KERNEY.QUILLEN
Special Assistant United States Attorney
VA Bar No. 66633
Defendant's Initials: a \
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