Plea Agreement — United States v. Adam Winston James

Summary

A plea agreement in United States v. Adam Winston James, Case No. 20-CR-327-JED, U.S. District Court for the Northern District of Oklahoma, filed 06/22/21 as Document 37 (19 pages). James agrees to plead guilty to aggravated identity theft under 18 U.S.C. § 1028A(a)(1) as charged in the Information. In the factual basis he admits that from on or about April 22, 2020, to on or about May 11, 2020, he executed a scheme to obtain Paycheck Protection Program loans for Velocity Innovations LLC by falsely representing to Regent Bank that the company had an average monthly payroll of $50,362.75, had 6 employees and was in operation on February 15, 2020. He agrees to restitution of $125,900.00 to Regent Bank, to a forfeiture money judgment of $125,900 and to a special assessment of $100 per felony count.

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Case 4:20-cr-00327-GKF Document 37 Filed in USDC ND/OK on 06/22/21 Page 1 of 19

IN THE UNITED STATES DISTRICT COURT
FOR THE NORTHERN DISTRICT OF OKLAHOMA

UNITED STATES OF AMERICA,
Plaintiff,
v. Case No. 20-CR-327-JED

ADAM WINSTON JAMES,

Defendant.

Plea Agreement

The United States of America, by and through Clinton J. Johnson, Acting
United States Attorney for the Northern District of Oklahoma, and Victor A.S. Régal,
Assistant United States Attorney, and the defendant, Adam Winston James, in person
and through counsel, Donte Mills and John Campbell, respectfully inform the Court
that they have reached the following plea agreement.

The defendant agrees to enter a voluntary plea of guilty to the following:

18 U.S.C. § 1028A(a)(1) —- Aggravated Identity Theft

as set forth in the Information in the instant case, Northern District of Oklahoma, and
admits to being in fact guilty as charged in the count to which the defendant is pleading

guilty.

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2. Waiver of Constitutional Rights

The defendant understands that, by pleading guilty, the following constitutional
rights will be relinquished:

a. the right to be indicted if proceeding by Information;

b. the right to plead not guilty;

C. the right to be tried by a jury, or, if the defendant wishes and with the
consent of the Government, to be tried by a judge;

d. at trial, the defendant has the right to an attorney, and if defendant could
not afford an attorney, the Court would appoint one to represent the defendant;

e. the defendant has the right to assist in the selection of the jury;

f. during trial, the defendant would be presumed innocent, and a jury
would be instructed that the Government has the burden to prove the defendant guilty
beyond a reasonable doubt and by a unanimous verdict;

g. the defendant has the right to confront and cross-examine witnesses
against the defendant;

h. if desired, the defendant could testify on the defendant’s own behalf and
present witnesses in the defendant’s defense;

i. if the defendant did not wish to testify, that fact could not be used against
the defendant, and a jury would be so instructed;

j. if the defendant were found guilty after a trial, the defendant would have
the right to appeal that verdict to determine if any errors had been committed during
trial that would require either a new trial or a dismissal of the charges; and

k. at trial, the defendant would be entitled to have a jury determine beyond
a reasonable doubt any facts which may have the effect of increasing the defendant’s
mandatory minimum or maximum sentence.

1. any rights and defenses defendant may have under the Excessive Fines
Clause of the Eighth Amendment to the United States Constitution to the forfeiture of

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property in this proceeding or any related civil proceeding, special or other assessment,
and any order of restitution.

By pleading guilty, the defendant will be giving up all of these rights. By pleading
guilty, the defendant understands that the defendant may have to answer questions
posed to defendant by the Court, both about the rights that the defendant will be giving
up and the factual basis for the defendant’s plea.

3. Appellate and Post-Conviction Waiver

In consideration of the promises and concessions made by the United States in
this plea agreement, the defendant knowingly and voluntarily agrees to the following
terms:

a. The defendant waives the right to directly appeal the conviction and
sentence pursuant to 28 U.S.C. § 1291 and/or 18 U.S.C. § 3742(a); except that the
defendant reserves the right to appeal from a sentence that exceeds the statutory
maximum;

b. The defendant expressly acknowledges and agrees that the United States
reserves all rights to appeal the defendant’s sentence as set forth in 18 U.S.C. § 3742(b),
and U.S. v. Booker, 543 U.S. 220 (2005); and

c. The defendant waives the right to collaterally attack the conviction and
sentence pursuant to 28 U.S.C. § 2255, including any assessment, forfeiture, restitution
order, the length of term of supervised release and any condition of supervised release,
except for claims of ineffective assistance of counsel.

The defendant expressly acknowledges that counsel has explained his appellate

and post-conviction rights; that the defendant understands his rights; and that the

defendant knowingly and voluntarily waives those rights as set forth above.

Adam WinstowJames

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4. Departure and Variance Waiver

In consideration of the promises and concessions made by the United States in
this plea agreement, the defendant knowingly and voluntarily agrees to the following:

a. the defendant agrees not to request, recommend, or file a motion seeking
a departure from the Guidelines range; and

b. the defendant agrees not to request, recommend, or file a motion seeking
a variance below the Guidelines range pursuant to the § 3553(a) factors.

5. Freedom of Information Act Waiver

The defendant waives all rights, whether asserted directly or by a representative,
to request or to 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. § 552a.

6. Rule 11 Rights Waiver

The defendant knowingly and expressly waives all of the rights afforded
defendant pursuant to the provisions of Rule 11(f) of the Federal Rules of Criminal
Procedure. In other words, after entry of a plea made pursuant to this plea agreement,
and in consideration thereof, the following shall be admissible against the defendant:

a. A plea of guilty which is later withdrawn or which the defendant seeks to
withdraw;

b. Any statement made in the course of any proceeding under Rule 11
regarding said plea of guilty;

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Cc. Any statement made in the course of plea discussions with an attorney
or agent for the Government, or which were made pursuant to a proffer letter
agreement, which result in a plea of guilty later withdrawn.

7. Waiver of Right to Jury Trial on Sentencing Factors

The defendant, by entering this plea, also waives the right to have facts that
determine the offense level under the Sentencing Guidelines (including facts that
support any specific offense characteristic or other enhancement or adjustment) (1)
charged in the Information, (2) proven to a jury, or (3) proven beyond a reasonable
doubt. The defendant explicitly consents to have the sentence based on facts to be
established by a preponderance of the evidence before the sentencing judge pursuant
to United States v. Crockett, 435 F.3d 1305 (10th Cir. 2006), and United States v.
Magallanez, 408 F.3d 672 (10th Cir. 2005), and to allow the Court to consider any
reliable evidence without regard to its admissibility at trial. The defendant explicitly
acknowledges that his plea to the charged offense authorizes the Court to impose any
sentence up to and including the maximum sentence set forth in the United States
Code. The defendant also waives all challenges to the constitutionality of the
Sentencing Guidelines.

8. Payment of Monetary Penalties

The defendant understands that the Court may impose a fine pursuant to the
Sentencing Guidelines. The defendant agrees, as a part of this agreement, to submit
to interviews by the United States Attorney’s Financial Litigation Unit regarding the

defendant’s financial status, and to complete and submit a financial statement, under

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oath, not later than two weeks after the date of this plea agreement. The defendant
understands that, by law, interest accrues on any remaining balance of the debt.

That monetary penalties imposed by the Court will be (i) subject to immediate
enforcement as provided for in 18 U.S.C. Section 3613, and (ii) submitted to the
Treasury Offset Program so that any federal payment or transfer of returned property
the defendant receives may be offset and applied to federal debts but will not affect the
periodic payment schedule.

9. Restitution for Offense of Conviction

The defendant understands that the Court can order the defendant to pay
restitution for the full loss caused by defendant’s conduct set forth above. The
defendant agrees to the entry of a Restitution Order for the full amount of the victims’
losses. At this time, the Government is aware that the following victims have suffered
the following losses:

Regent Bank $125,900.00

7136 S Yale Ave, #100

Tulsa, Oklahoma 74136

The defendant understands that restitution is mandatory without regard to the
defendant’s ability to pay.

10. Restitution not Dischargeable in Bankruptcy

The defendant further agrees that any amount ordered by the Court to be paid
as restitution may not be discharged, in whole or in part, in any bankruptcy

proceeding.

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11. Forfeiture Agreement

The defendant agrees to the entry of a criminal forfeiture money judgment,
pursuant to 18, U.S.C., §§ 982(a) and 1028(b)(5), and 28, U.S.C., § 2461(c), in the
amount of $125,900, representing proceeds he obtained, directly or indirectly, as a
result of the offense.

The defendant agrees to forfeit substitute property, up to the value of the
property described above, if, by any act or omission of the defendant, the property
described above, or any portion thereof, cannot be located upon the exercise of due
diligence; has been transferred or sold to, or deposited with, a third party; has been
placed beyond the jurisdiction of the court; has been substantially diminished in value;
or has been commingled with other property which cannot be divided without
difficulty.

The defendant further understands that forfeiture is part of the sentence that will
be imposed in this case and waives any failure by the Court to advise him of this,
pursuant to Rule 11(b)(1)(), at the time his guilty plea is accepted. The defendant
further understands that, pursuant to Rule 32.2(b)(4)(A), the order of forfeiture will
become final as to the defendant upon entry. The defendant waives notice of the
forfeiture in the charging instrument, of announcement of the forfeiture at sentencing,
and incorporation of the forfeiture in the judgment. The defendant also waives all
constitutional and statutory challenges in any manner (including direct appeal, habeas
corpus, or any other means) to any forfeiture carried out in accordance with this plea

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agreement on any grounds, including that the forfeiture constitutes an excessive fine
or punishment.

12. Special Assessment

The defendant hereby agrees to pay the total amount required for the Special
Monetary Assessment ($100 per felony count) to the United States District Court Clerk
before the time of the sentencing hearing or as directed by the District Court.

13. Factual Basis and Elements

The elements that the United States must prove beyond a reasonable doubt in
order to convict under 18 U.S.C. § 1028A(a)(1) are as follows:

a. The defendant knowingly transferred, possessed, or used;

b. Without lawful authority;

c, The means of identification of another person;

d. During and in relation to bank fraud as defined in 18 U.S.C. § 1344.

The elements that the United States must prove beyond a reasonable doubt in
order to convict under 18 U.S.C. § 1344 are as follows:

a. The defendant knowingly executed or attempted to execute a
scheme or artifice to defraud Regent Bank or a scheme or artifice

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to obtain money or property from Regent Bank by means of false
or fraudulent pretenses, representations, or promises;

b. Regent Bank was a financial institution within the meaning of the
law because its deposits were insured by the Federal Deposit
Insurance Corporation;

c. As to a § 1344(1) “scheme to defraud,” the defendant acted with
intent to defraud, that is, with intent to deceive, and placed Regent
Bank at risk of civil liability or financial loss.

d. As to a § 1344(2) “fraudulent pretenses scheme,” the false or
fraudulent pretenses, representations, or promises that the
defendant made were material, meaning they would naturally
tend to influence, or were capable of influencing the decision of,
Regent Bank.

With regard to the factual basis required by Federal Rule of Criminal Procedure
11(6)(3), the defendant agrees and stipulates that there is a factual basis for the plea of
guilty and relieves the United States of any further obligation to adduce such evidence.

The defendant, ADAM WINSTON JAMES, admits knowingly, willfully and
intentionally committing or causing to be committed the acts constituting the crime
alleged in the Information in the instant case, and confesses to the Court that the
defendant is, in fact, guilty of such crime:

From on or about April 22, 2020, to on or about May 11, 2020, I devised and
executed a scheme to defraud banks and to obtain money from banks by means of
material false and fraudulent pretenses, representations, and promises. Specifically, I
admit that for the purpose of securing loans for a company, Velocity Innovations LLC
(“Velocity Innovations”), that I claimed to own and operate pursuant to the Paycheck
Protection Program (PPP) administered by the United States Small Business
Administration, I knowingly and intentionally made false representations to Regent
Bank, a federally-insured financial institution located in the Northern District of
Oklahoma. To execute the scheme, I falsely represented in a PPP “Borrower
Application Form” submitted to Regent Bank that Velocity Innovations had an
average monthly payroll of $50,362.75; had 6 employees; was in opeyation on

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February 15, 2020; and would use the requested loan funds to retain workers and
maintain payroll or make mortgage interest payments, lease payments, and utility
payments, as specified under the Paycheck Protection Program Rule. I also knowingly
and intentionally certified falsely in the PPP “Borrower Application Form” submitted
to Regent Bank that the information provided in the application and supporting
documents was true and accurate in all material respects. I knew when I made these

representations that they were false, and I knew that what I was doing was wrong.

The ® employees reflected on the “Borrower Application Form” were HR, SS,
EU, DM, GL, and LM. Although Velocity Innovations did not in fact employ any
KE of them, I knowingly used their names and their Social Security Numbers to create
V fraudulent W-2s, which I then transferred to Regent Bank for the purpose of securing
a PPP loan. None of them gave me the authority to use their means of identification
for that purpose.

In furtherance of the scheme, I conspired with Rafael Maturino to create the
false list of employees that I used for my PPP application for Velocity Innovations.
The purpose of our illegal scheme was to enrich ourselves unlawfully by fraudulently
obtaining loan proceeds from banks pursuant to the federal Paycheck Protection

Program.
Ua. \ ner y /12. | 2° 2)
ADAM WINSTON JAMES Date
Defendant

14. Further Prosecution

The United States shall not initiate additional criminal charges against the
defendant in the Northern District of Oklahoma that, as of the date of the defendant’s
acceptance of this agreement, arise from its investigation of the defendant’s actions
and conduct giving rise to the instant Information, save and except crimes of violence
and criminal acts involving violations investigated by the United States Internal

Revenue Service. The defendant understands, however, that this obligation is subject

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to all “Limitations” set forth below, and that the United States Attorney’s Office for
the Northern District of Oklahoma is free to prosecute the defendant for any illegal
conduct (i.e., violation of federal criminal laws) not discovered by or revealed to the
Government during its investigation or occurring after the date of this agreement.

15. Dismissal of Remaining Counts

If the Court finds the defendant’s plea of guilty to be freely and voluntarily made
and accepts the plea, then the United States will move, at the appropriate time, to
dismiss the remaining counts in the instant case, if any, as to this defendant.

If the defendant’s guilty plea is rejected, withdrawn, vacated, or reversed at any
time, the United States will be free to prosecute the defendant for all charges of which
it then has knowledge, and any charges that have been dismissed will be automatically
reinstated or may be re-presented to a grand jury with jurisdiction over the matter. In
such event, the defendant hereby waives any objections, motions or defenses based
upon the applicable statute of limitations, the Speedy Trial Act, or constitutional
restrictions as to the time of bringing such charges.

16. Acceptance of Responsibility

Provided the defendant clearly demonstrates acceptance of responsibility, the
United States agrees to recommend a two-level reduction in offense level pursuant to
U.S.S.G. § 3E1.1. The United States agrees to file a motion recommending that the
defendant receive an additional one-level reduction pursuant to U.S.S.G. § 3E1.1(b) if

the defendant is otherwise eligible therefor. The sentencing judge is in a unique

1]
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position to evaluate the acceptance of responsibility, and the Court’s determination
will provide the final approval or disapproval of any Section 3E1.1 point level
reduction for timely acceptance of responsibility.

The obligations of the Government herein, relative to acceptance of
responsibility are contingent upon the defendant's continuing manifestation of
acceptance of responsibility as determined by the United States. If the defendant
falsely denies, or makes conflicting statements as to, his involvement in the crime to
which he is pleading, falsely denies or frivolously contests relevant conduct that the
Court determines to be true, willfully obstructs, or attempts to obstruct or impede the
administration of justice as defined in U.S.S.G. § 3C1.1, or perpetrates or attempts to
perpetrate crimes while awaiting sentencing, or advances false or frivolous issues in
mitigation, the United States expressly reserves the right to withdraw any
recommendation regarding acceptance of responsibility without breaching the
agreement.

17. Sentence

a. Imprisonment
The defendant acknowledges that under 18 U.S.C. § 1028A(a)(1) the minimum
mandatory statutory sentence and the maximum statutory sentence is 2 years of
imprisonment, and a fine of not more than $250,000 or twice the pecuniary gain/loss

caused by the defendant’s acts.

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b. Supervised Release

Additionally, the defendant is aware, if imprisonment is imposed, that the Court
shall include as part of the sentence a requirement that the defendant be placed on a
term of supervised release after imprisonment not to exceed one year.

If the term of supervised release for any count of conviction is revoked, the
defendant may be imprisoned for an additional term not to exceed the term of
imprisonment authorized in 18 U.S.C. § 3583(e)(3) for the offense of conviction, with
no credit being given for any time served while on supervised release. Further, the
Court may impose another term of supervised release following any term of
imprisonment imposed for a violation of supervised release conditions, and this term
of supervised release may not exceed the term of supervised release originally
authorized by statute for the offense of conviction less any term of imprisonment that
was imposed upon revocation of supervised release (18 U.S.C. § 3583(e) and (h)). Ifa
second or subsequent term of supervised release is revoked, the Court may impose
another term of imprisonment not to exceed the difference between any imprisonment
imposed for a prior revocation of supervised release for the offense of conviction and
the term of imprisonment authorized pursuant to 18 U.S.C. § 3583(e)(3). Accordingly,
the original term of imprisonment when combined with any term of imprisonment
arising from revocations of supervised release, may result in a total amount of

imprisonment greater than the statutory maximum term for the offense of conviction.

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c. Guidelines

The defendant is aware that the Sentencing Guidelines promulgated pursuant
to the Sentencing Reform Act of 1984 at 18 U.S.C. § 3551 through § 3742, and 28
U.S.C. § 991 through § 998, are advisory. The district courts, while not bound to apply
the Sentencing Guidelines, must consult those Guidelines and take them into account
when sentencing. See 18 U.S.C.A. § 3553(a).

The sentence imposed in federal court is without parole. The defendant is
further aware that the sentence has not yet been determined by the Court, that any
estimate of the likely sentence received from any source is a prediction, not a promise,
and that the Court has the final discretion to impose any sentence up to the statutory
maximum. The defendant further understands that all recommendations or requests
by the United States pursuant to this agreement are not binding upon the Court.

If the sentencing Court should impose any sentence up to the maximum
established by statute, the defendant cannot, for that reason alone, withdraw
defendant’s guilty plea, but will remain bound to fulfill all of defendant’s obligations
under this agreement.

Nothing in this plea agreement, save and except any stipulations contained
herein, limits the right of the United States to present to the Court or Probation Office,
either orally or in writing, any and all facts and arguments relevant to the defendant’s
sentence that are available to the United States at the time of sentencing. The

defendant acknowledges hereby that relevant conduct, that is, conduct charged in any

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dismissed count and all other uncharged related criminal activities, will be used in the
calculation of the sentence. The United States reserves its full opportunity to speak
pursuant to Rule 32(i)(4)(A)(iii) of the Federal Rules of Criminal Procedure.

The defendant further understands that the sentence to be imposed upon the
defendant will be determined solely by the sentencing judge, and that the sentencing
judge is not bound by the following stipulations. The United States cannot and does
not make any promise or representation as to what sentence the defendant will receive.

18. Stipulations

For purposes of U.S.S.G. § 2B1.1(b)(1)(E), the parties stipulate that the “loss”
was more than $95,000 and less than $150,000.

It is understood that neither the Court nor the United States Probation Office is
bound by the foregoing stipulation, either as to questions of fact or as to determination
of the correct advisory sentencing guideline calculation.

Having been fully apprised by defense counsel of defendant’s right to seek
compensation pursuant to Public Law 105-119, the defendant WAIVES any and all
such right, and stipulates that defendant is not a “prevailing party” in connection with
this case.

19. Limitations

This plea agreement shall be binding and enforceable upon the Office of the
United States Attorney for the Northern District of Oklahoma, but in no way limits,

binds or otherwise affects the rights, powers, duties or obligations of any state or local

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law enforcement agency, administrative or regulatory authorities, civil or
administrative enforcement, collection, bankruptcy, adversary proceedings or suits
which have been or may be filed by any governmental entity, including without
limitation, the Internal Revenue Service, the Tax Division of the Department of Justice
and the trustee in bankruptcy.

20. Breach of Agreement

In the event either party believes the other has failed to fulfill any obligations
under this agreement, then the complaining party shall, in its discretion, have the
option of petitioning the Court to be relieved of its obligations herein. Whether or not
a party has completely fulfilled all of its obligations under this agreement shall be
determined by the Court in an appropriate proceeding at which any disclosures and
documents provided by either party shall be admissible and at which the complaining
party shall be required to establish any breach by a preponderance of the evidence.
The defendant hereby WAIVES any right under Rule 11(d) and (e) of the Federal
Rules of Criminal Procedure to withdraw from defendant’s plea and this agreement,
save and except under circumstances where the Court rejects the plea agreement under
Rule 11(c)(5) and except for the limited reasons outlined above in this paragraph.

In the event that ADAM WINSTON JAMES, after entry of a plea of guilty,
unsuccessfully attempts to withdraw the defendant’s plea of guilty, the United States
may continue to enforce the agreement but will no longer be bound by any particular

provision in this agreement. This provision will not have any continued vitality if it is

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determined by the Court that the United States acted in bad faith to bring about the
attempted withdrawal of plea.

21. Conclusion

No agreements, representations or understandings have been made between the
parties in this case, other than those which are explicitly set forth in this plea agreement
and the Plea Agreement Supplement that the United States will file in this case (as is
routinely done in every case, even though there may or may not be any additional
terms) and none will be entered into unless executed in writing and signed by all of the
parties.
SO AGREED:

CLINTON J. JOHNSON
ACTING UNIT ATES ATTORNEY

Assistant United States Attorney

DONTE MILLS ~ Dated
Attorney for Defendant

vt dO LU Ly [22] 202\

rney for Defendant

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ADAM WINS®ON JAMES Dated
Defendant

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I have read this agreement and carefully reviewed every part of it with my
attorney. I understand it, and I voluntarily agree to it. Further, I have consulted with
my attorney and fully understand my rights with respect to sentencing which may
apply to my case. No other promises or inducements have been made to me, other
than those contained in this pleading. In addition, no one has threatened or forced me
in any way to enter into this agreement. Finally, I am satisfied with the representation

of my attorney if\this matter.

ADAM WINSYPN JAMES Dated | b
Defendant

I am counsel for the defendant in this case. I have fully explained to the
defendant the defendant’s rights with respect to the pending Information. Further, I

have reviewed the provisions of the Sentencing Guidelines and Policy Statements and

I have fully explained to the defendant the provisions of those Guidelines which may
apply in this case. I have carefully reviewed every part of this plea agreement with the
defendant. To my knowledge, the defendant’s decision to enter into this agreement is

an informed and voluntary one.

a 2 6 -A2 - ROH

DONTE MILLS Dated
Counsel for the Defendant

CAMPBELL
sel for the Defendant

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Dated


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