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Home Court filings U.S. v. Gladys Harun Sentencing Hearing Transcript — United States v. Gladys Harun (3:23-cr-3)

Court filing

Sentencing Hearing Transcript — United States v. Gladys Harun (3:23-cr-3)

Summary

A transcript of the sentencing hearing in United States of America v. Gladys Harun, No. 3:23-cr-00003-DHB-BKE, in the U.S. District Court for the Southern District of Georgia, Dublin Division, held January 23, 2024 before Judge Dudley H. Bowen, Jr. and filed October 17, 2024 as Document 48. The court notes the defendant pleaded guilty on April 27, 2023 to count one of an Information charging making false statements. The hearing turns on defense objections to the Presentence Investigation Report's restitution figures: defense counsel puts the loans and grants received at $504,156, and the government responds with a total of $552,649.14 covering loan amounts and lender fees. Two federal special agents are sworn and testify to the individual loan, fee and interest figures. The 61-page transcript ends with the reporter's certificate and the court's remand of the defendant.

Summary drafted by a model from the document's text below and checked by script against that text before publication. It is a navigation aid, not a reading of what the document proves. Where AI is used

No. 3:23-cr-00003-DHB-BKE · Doc. 48 · Docket on CourtListener

Full text

Case 3:23-cr-00003-DHB-BKE

Document 48

Filed 10/17/24

Page 1 of 61

UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF GEORGIA
DUBLIN DIVISION
United States of America,

)
)
Plaintiff,
)
)
vs.
)
)
Gladys Harun,
)
)
Defendant.
)
______________________________)

Case No. 3:23CR3

SENTENCING HEARING
BEFORE THE HONORABLE DUDLEY H. BOWEN, JR.
UNITED STATES DISTRICT COURT JUDGE
TUESDAY, JANUARY 23, 2024; 1:59 P.M.
FOR THE PLAINTIFF:
L. Alexander Hamner, Esquire
U.S. Attorney's Office
22 Barnard Street, Suite 300
Savannah, Georgia 31401
(912)652-4422
FOR THE DEFENDANT:
Johnny Emmett Clyde Vines, Esquire
Johnny Vines, P.C.
Post Office Box 1422
Metter, Georgia 30439
(912)243-0519
OFFICIAL COURT REPORTER:
Lisa H. Davenport, RPR, FCRR
Post Office Box 5485
Aiken, South Carolina 29804
(706)823-6468


Case 3:23-cr-00003-DHB-BKE

Document 48

Filed 10/17/24

Page 2 of 61

INDEX
WITNESS

DIRECT

Brian Jack,
By Mr. Hamner
Justin Lott,
By Mr. Hamner
By Mr. Vines

CROSS

REDIRECT

6
12

Emanuel Githinji,
By Mr. Vines

40

Ann Wangui,
By Mr. Vines

42

Simon Juchu,
By Mr. Vines

43

15

EXHIBITS
NO.

IDENTIFICATION

EVD.

(None offered)

RECROSS


Case 3:23-cr-00003-DHB-BKE

Document 48

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Page 3 of 61
3

1

(Call to Order at 1:59 p.m.)
THE CLERK:

2

Case 3:23CR3, United States of America

3

versus Gladys Harun, is called for sentencing.

4

the United States, Alex Hamner.

5

Vines.

Representing

Representing defendant, Johnny

6

MR. HAMNER:

Alex Hamner on behalf of the United

7

States, Your Honor.

8

MR. VINES:

Afternoon, Judge.

9

THE COURT:

Ms. Gladys Harun, on April 27, 2023, you

We're ready to proceed.
The defense is ready.

10

entered into a plea of guilty as to count one of an Information

11

charging you with making false statements, and that, of course,

12

in a violation of federal law.

13

read and discuss the Presentence Investigation Report with your

14

lawyer?

15

THE DEFENDANT:

16

THE COURT:

17

objection.

Have you had the opportunity to

Yes, sir.

Thank you.

Now, Mr. Vines, I understand there is an

Is that correct?

18

MR. VINES:

Yes, Your Honor, approximately three.

19

THE COURT:

All right.

20

up to three.

21

first one.

22

Well, we can count all the way

Approximation not necessary.

MR. VINES:

Thank you, Your Honor.

Tell me about the

Your Honor,

23

objection one deals with paragraphs 69 and 41 of the victim

24

impact and restitution.

25

somewhat different from as calculated by the U.S. Probation,

Your Honor, our calculations are


Case 3:23-cr-00003-DHB-BKE

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Page 4 of 61
4

1

Your Honor, and so, therefore, we're objecting to that in that,

2

Your Honor, my client -- according to our estimates she

3

received a total of $504,156 in loans and grants, Your Honor,

4

and she provided documentation to the United States Probation

5

Office that showed that she used those for legitimate purposes

6

regarding her business and, therefore, we're arguing that the

7

restitution amount is therefore flawed.

8
9
10

THE COURT:

All right.

Mr. Hamner, what do you have

to respond there?
MR. HAMNER:

Your Honor, the -- it's kind of hard to

11

respond in the sense in that the information that we have is

12

the same as probation has.

13

by Gladys and by those that she assisted with obtaining some

14

EIDL loans -- specifically, Jacqueline Black for a PPP loan;

15

Jane Njeru for an EIDL loan, and Esther whose last name I don't

16

know how to pronounce for an EIDL loan as well.

17

amounts total to $552,649.14.

It's the amounts that were received

Those total

18

I have agents -- Special Agent Brian Jack of the IRS

19

and Special Agent Justin Lott from the SBA -- who can testify

20

as to those amounts and how they came up with those figures --

21

specifically being the amounts that would cover the loan amount

22

in addition to the lender fees and I am prepared to present

23

them to the Court.

24

THE COURT:

25

Well, let's be direct about it.

offense here is making false statements --

The


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Page 5 of 61
5

1

MR. HAMNER:

Yes, sir.

2

THE COURT:

-- in the acquisition of EIDL loans,

3

grants or other loans.

4

spent if it was obtained wrongfully.
Now, Mr. Vines, is that a concept that you are

5
6

It doesn't matter how the money was

disagreeing with?

7

MR. VINES:

Unfortunately not, Judge.

8

THE COURT:

All right.

Now you say in the objection

9

that the money was spent "for business purposes".

10

this accounting that shows that?
MR. VINES:

11

Where is

Your Honor, my client has provided me a

12

statement from Embrace Africa that had laid out everything that

13

it was spent on, Your Honor.

14

the Presentencing Report, Your Honor.

It should be attached as part of

15

THE COURT:

And this is it?

16

MR. VINES:

Unfortunately.

17

THE COURT:

All right.

18
19
20
21

Okay.

Y'all have a seat for a

moment.
I think under the circumstances it's best to get a
testimonial record of the amounts, Mr. Hamner.
MR. HAMNER:

Yes, sir.

I will start with Special

22

Agent Brian Jack.

23

so they can properly identify the amounts.

24
25

THE COURT:

Your Honor, I am trying to get the paperwork

Sure.

(Brian Jack is duly sworn.)


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6

(Brian Jack - Direct by Mr. Hamner)
THE CLERK:

1
2

Have a seat.

State your

name spelling the same and your occupation.
THE WITNESS:

3
4

Please come up.

Brian Jack.

B-R-I-A-N J-A-C-K, Special

Agent, IRS Criminal Investigation.
DIRECT EXAMINATION

5
6

BY MR. HAMNER:

7

Q

8

summarizing -- I mean briefly -- the extent of the

9

investigation you conducted on this?

10

A

11

Ms. Harun, at her business in middle Georgia.

12

if it was Dublin.

13

Q

14

a hard time hearing you.

15

A

16

off by interviewing Ms. Harun at her place of employment and I

17

don't recall if it was Dublin or Macon, but it was one of her

18

Jackson Hewitt enterprises and we confronted her about her PPP

19

loans at the time and she, essentially, just denied and stated

20

that she was entitled to the money that was obtained.

21

Q

22

referring to?

23

A

24

received.

25

my recollection the first one was a PPP loan for approximately

Thank you, Special Agent Jack.

Sure.

Would you mind briefly

So we started by interviewing the defendant,
I don't recall

I think it might have been Dublin.

I am going to ask you to speak up a little bit.

Okay.

Yeah, I'll talk a little bit louder.

Let me back up for a second.

I'm having

So we started

What PPP loans are you

Talking about three specific PPP loans, all of which she
One of -- I'll go chronologically.

To the best of


Case 3:23-cr-00003-DHB-BKE

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Page 7 of 61
7

(Brian Jack - Direct by Mr. Hamner)
1

$46,033.

That one was obtained from Wells Fargo.

Secondly, there was a PPP loan for approximately $25,000

2
3

and that number could be off a little bit -- 25, $26,000.

That

4

one was a Truist -- I believe it was a Truist PPP loan and

5

then, thirdly, was the big one and that one was obtained

6

from -- Lendistry was the lender -- Lendistry Bank.

7

either doing business as BSD Capital or vice versa and that one

8

was approximately $299,913.

9

Ms. Harun claimed that she was entitled to but also physically

10

obtained the money.

It was

Those are the three PPP loans that

There were four other individuals that Ms. Harun assisted

11
12

in preparing their either PPP or EIDL loan/grant and all of

13

which we talked to and all of them said that they did not have

14

businesses during the timeframe that SBA required businesses to

15

have actually already been established.

16

Q

17

one of those individuals -- Melinda Hoven.

18

A

19

or about 2020 -- mid-2020 to the best of my memory -- but the

20

requirement to have obtained a PPP loan was right around

21

mid-February of 2020.

22

business prior to mid-February of 2020.

23

had not started at that point; therefore, she was not entitled

24

to have obtained any money.

25

Q

Okay.

So let me stop you for a second.

Melinda Hoven.

Okay.

Let's start with

She started a t-shirt printing business in

Like, you already had to have had a
Her t-shirt company

Do you recall approximately the amount from


Case 3:23-cr-00003-DHB-BKE

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Page 8 of 61
8

(Brian Jack - Direct by Mr. Hamner)
1

Ms. Hoven's PPP loan?

2

A

I would have to go through my notes here.

3

Q

Please do.

4

can get.

5

A

6

was 15,625.

7

Q

8

fees that were paid?

9

A

10

of $272.69.

11

Q

12

fraudulent because her business was not in existence at the

13

time?

14

A

Correct.

15

Q

Okay.

16

A

Jacqueline Black was the same exact situation.

17

no -- there was no business during the time that she was

18

required to have had a business so she did not qualify.

19

Q

Who prepared the PPP loan?

20

A

I'm sorry?

21

Q

Who prepared the loan?

22

A

Ms. Harun.

23

Q

The application?

24

A

Yes, and the same thing with Ms. Hoven.

25

hers -- prepared hers as well.

I think the Court wants as exact figures as you

So please provide those.

Exact figures.

Okay.

Yes.

Sure.

So the amount of Ms. Hoven's loan

And in addition to that loan were there SBA lender

Yes.

Lender fees of $2500 and then there is interest

So collectively that's 18,397.69.

And Ms. Hoven's application for PPP was determined to be

Let's move on to Jacqueline Black, please.
There was

Ms. Harun provided


Case 3:23-cr-00003-DHB-BKE

Document 48

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Page 9 of 61
9

(Brian Jack - Direct by Mr. Hamner)
1

Q

And how much was the amount for the PPP loan that was given

2

by SBA to Ms. Jacqueline Black?

3

A

Ms. Black received $8,240 --

4

Q

Were there lender fees?

5

A

-- $2,500, interest $43.26.

6

10,783.26.

I'll move on when you're ready.

7

Q

Okay.

Let's move on to Jane Njeru.

8

A

Jane Njeru.

9

EIDLs.

10

business and Ms. Njeru did not.

11

obtained from SBA in the form of an EIDL $116,300.

12

no lender fees in that situation, but there was interest of

13

$3,510.71.

Collectively, that's 119,810.71.

14

Q

We'll come back to her in just a second.

15

Esther N-J-O-R-O-G-E?

16

A

17

thing applies here was that she just didn't have a business

18

when she was required to have a business.

19

advance of $15,000.

20

So in total $15,000.

21

Q

22

Ms. Harun had obtained.

23

applications?

24

A

25

cases, but the big one -- Lendistry -- was a -- I would call it

This was EIDL.

Same principle applies.

Okay.

Esther Njoroge.

Okay.

Collectively, that's

The following one will be
You had to have had an actual
She told us she did not.

She

There was

What about

This was another EIDL advance and the same

She received an EIDL

Therefore, no lender fees and no interest.

All right.

Let's go back to the PPP loans that
What was fraudulent about her

All three of them were -- it was a combination in some


Case 3:23-cr-00003-DHB-BKE

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10

(Brian Jack - Direct by Mr. Hamner)
1

a gross inflation of her payroll.

2

secure a PPP loan was heavily driven by payroll, by average

3

monthly payroll specifically during 2019 and then if they opted

4

to use 2020 they could do so, and the payroll was just grossly

5

inflated like tenfold.

6

It was $299,913 and the best I could tell she was actually

7

entitled to approximately $25,000.

8

number, but it was right around $25,000, not 299,913.

9

Q

10

three of these PPP loans?

11

A

12

one the payroll was also inflated and it was also done for the

13

other PPP amount, and let me flip through here, but I believe

14

that one was obtained from Truist.

15

$25,000.

16

know where that is in this folder, but it was approximately

17

25,000.

18

Q

19

loan at $46,440.36.

20

A

It sounds pretty close, yes.

21

Q

Okay.

22

some of the restitution that's going to be owed based on these

23

figures.

24

restitution in the binder that you have?

25

A

Okay.

So the PPP calculation to

So she obtained approximately $300,000.

I have never ran the exact

And this same form of fraud was perpetrated for all

It was perpetrated for the Wells Fargo on $46,033.

That

That one was around

Let me see if I can find the exact number.

I don't

I can find it if you need me to.

Let me say it this way.

Probation calculated the first PPP

Does that sound like an accurate figure?

Well, I think the Court is going to be determining

So do you have the actual amounts that are needed for

I don't know.


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11

(Brian Jack - Direct by Mr. Hamner)
1

Q

Okay.

2

A

This was not prepared by me.

3

Q

That's okay.

4

Your Honor, if I may call Special Agent Justin Lot.

5

are the questions I had for Brian Jack regarding the

6

investigation.

He was the lead case agent in the

7

investigation.

Special Agent ---

THE COURT:

8

Let me just be direct, Mr. Hamner.

These

This

9

objection has been outstanding for quite a while.

It is

10

obvious that we need to establish a record for it.

I would

11

have thought that these witnesses might be a little better

12

prepared.

13

MR. HAMNER:

Your Honor, I believe that Special Agent

14

Lott is the one that prepared the actual figures.

15

sitting right here behind me.

16

and testify.

17

THE COURT:

Okay.

He is

I was going to have him come up

Well, thank you very much,

18

Mr. Jack, but, now, Mr. Vines, do you have any questions for

19

Mr. Jack on what he's told you so far?

20
21

MR. VINES:

Your Honor, since the case agent is coming

up, no questions for this witness.

22

THE COURT:

23

Thank you, Mr. Jack.

24

MR. HAMNER:

25

Your Honor.

All right.

Thank you.

We would call Special Agent Justin Lott,


Case 3:23-cr-00003-DHB-BKE

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Page 12 of 61
12

(Justin Lott - Direct by Mr. Hamner)
(Justin Lott is duly sworn.)

1

THE CLERK:

2
3

Please state your name for the record and

your occupation.
THE WITNESS:

4

My name is Justin Lott.

Last name is

5

spelled L-O-T-T.

I am a Special Agent with the United States

6

Small Business Administration, Office of Inspector General.
DIRECT EXAMINATION

7
8

BY MR. HAMNER:

9

Q

10

is the amounts that are owed in restitution; specifically, the

11

amount that Gladys Harun received for her PPP loans.

12

A

Yes.

13

Q

As well as the amount that was received by Melinda Hoven,

14

Jacqueline Black, Jane Njeru, Esther Njoroge.

Special Agent Lott, the question that we have at this time

Would you be so kind as to give me the figures for those?

15
16

A

Yes, I will.

Starting with Embrace Africa DBA Jackson

17

Hewitt Tax associated with Gladys Harun, PPP loan ending 7702,

18

she received $46,033.

19

lender $2,301.65 in lender fees and interest of $407.36 for a

20

total of $48,742.01.

21

Q

Okay.

22

A

Next we have for Gladys Harun, PPP loan ending 8907.

23

received $20,710.

24

$2,500 in lender fees, interest of $77.09 for a total of

25

$23,287.09.

In addition to that the SBA paid the

She

In addition to that amount the SBA paid out


Case 3:23-cr-00003-DHB-BKE

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13

(Justin Lott - Direct by Mr. Hamner)
Next was PPP loan ending 9010.

1

That was for Embrace

2

Africa.

The loan amount she received was $299,913.

3

fees paid out by the SBA were $14,995.65.

4

Q

I'm sorry.

5

A

14,995.65.

6

Q

Thank you.

7

A

And the interest for that loan was $2,062.42.

8

to $316,971.07.

Did you say 995 or 955?

Next was the PPP loan for Melinda Hovan.

9

The lender

That totals

That's PPP loan

10

ending 8608.

The total amount she received was $15,625.

The

11

SBA paid out lender fees of 2,500 as well as interest totaling

12

$272.69 for a total amount of $18,397.69.
Next we had EIDL advances that were paid out Njoroge.

13
14

totaled to $15,000.

There was no lender fees or interest

15

associated with that.

It was just a total of 15,000.

Next was the EIDL ending 9104 for Jane Njeru.

16

That

The total

17

amount of the loan she received was $116,300.

That was a

18

combination of the loans and the EIDL grants and advances she

19

received.

20

funded directly through the SBA and not PPP lenders, but the

21

interest calculated on that loan was $3,510.71 for a total of

22

$119,810.71.

23

Q

Okay.

24

A

The last was PPP loan ending 8710 for Jacqueline Black.

25

She received $8,240, lender fees paid out of $2,500, interest

There was no lender fee for that because it was


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14

(Justin Lott - Direct by Mr. Hamner)
1

of $43.26 for a total of $10,783.26.

2

Q

Now ---

3

THE COURT:

4

THE WITNESS:

5

THE COURT:

6

THE WITNESS:

Ten thousand how much?
I'm sorry, sir?
Ten thousand and how much?
$10,783.26.

And collectively my

7

calculation comes to $552,991.83 which is just, I believe, two

8

or $300 just over what probation's calculation was.

9

Q

10

of $273 that was previously mentioned?

11

A

12

interest of roughly two to $300 for Melinda Hoven.

13

Q

14

these figures is I believe that since probation prepared this

15

report Jane Njeru had paid approximately $6,101.23 back on her

16

EIDL loan.

17

A

18

calculated in December was $113,913.95.

19

Q

20

had mentioned before down by $6,101.23; correct?

21

sound about right?

22

A

23

sounds about right.

24

MR. HAMNER:

25

And I believe that came from the interest -- the interest

Yes, I believe in our original calculation we left off

Okay.

And the one final thing I want to bring up with

Is that right?

Approximately, her current balance owed as of when this was

Which if I am correct would bring the total amount that you

Sounds about right.

Does that

I don't have a calculator with me, but

Your Honor, I have no further questions

regarding the amounts that are owed to the SBA.


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15

(Justin Lott - Cross by Mr. Vines)
THE COURT:

1
2

Mr. Vines, you want to ask any questions

of Mr. Lott?

3

MR. VINES:

Yes, Your Honor.

4

THE COURT:

All right.
CROSS EXAMINATION

5
6

BY MR. VINES:

7

Q

So Special Agent?

8

A

Yes, sir.

9

Q

Special Agent, so I just want to get this straight.

10

Ms. Jane -- what's her last name?

11

A

Njeru.

12

Q

$119,810.71.

13

payments on it?

14

A

15

interest that has accrued on that loan since it has not been

16

paid in full was $3,510.71.

17

Q

18

payments on it?

19

A

20

that loan, yes.

So

I am not sure if I am saying that correctly.
She actually received that and she's making

She received physically $116,300 and in addition to that

The long and short is that she received it; she's making

She or somebody else has started making payments towards

21

MR. VINES:

Thank you.

No further questions.

22

MR. HAMNER:

I have no further questions for the

23

witness, Your Honor.

24

THE COURT:

25

for me, Special Agent Lott.

I'm thinking.

Go back to the Njeru loan

What were the circumstances for


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16

1

the origination of that loan?

2

THE WITNESS:

3

THE COURT:

4

THE WITNESS:

5

For Ms. Jane Njeru?
Yes.
The total calculated for the loan plus

the interest accrued was $119,810.71.

6

THE COURT:

Well, what did Ms. Harun have to do with

7

the initiation of that loan?

8

THE WITNESS:

The loan for Ms. Jane Njeru, I believe

9

if memory serves me correct, that her loan application actually

10

identified Ms. Gladys Harun on the application itself as the

11

preparer of the application.

12

address and some other methods and we also interviewed Ms. Jane

13

Njeru out in Washington state who admitted that Ms. Gladys

14

prepared the application on her behalf and was paid a fee for

15

doing so.

16

THE COURT:

17

THE WITNESS:

18

THE COURT:

19

THE WITNESS:

It was also tied via the IP

Well, who got the money?
The money went to Ms. Jane Najero.
Okay.
Minus a portion that she indicated was

20

paid to Ms. Gladys.

21

THE COURT:

And what portion was that?

22

THE WITNESS:

I can't recall directly.

23
24
25

I want to say

if memory serves me roughly $1,000, I believe.
THE COURT:

Well, I am trying to get to some

understanding of the importance of that rather large amount.


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17

1

Is it fair to say of all of the loans that you saw this is the

2

one that more likely approaches some legitimacy?
THE WITNESS:

3
4

Ms. Jane Njeru's loan had no legitimacy

at all.
THE COURT:

5

All right.

6

A

7

in operation at the time and, therefore, would not have been

8

eligible for any EIDL or PPP funds.

9
10

In fact, Ms. Jane explained to us that she had no business

THE COURT:

But in any event, she's the one that got

the money for it?

11

THE WITNESS:

That is correct.

12

THE COURT:

As far as you know.

13

THE WITNESS:

-- the funds.

She received ---

We identified the funds

14

went to Ms. Jane Njeru and I believe approximately half of that

15

money was shared with her sister Esther Njoroge which the

16

proceeds were used towards funding education for children and I

17

believe a boat purchase in Kenya, Africa.

18

THE COURT:

19

THE WITNESS:

20

THE COURT:

According to her statement.
That's correct.
All right.

Did you review the documents

21

that were supplied to the probation office here as an

22

explanation of where all this money went?

23
24
25

THE WITNESS:

I did have a chance to read through the

explanation of how the money was spent.
THE COURT:

And tell me what your conclusion was when


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1

you saw that.
THE WITNESS:

2

My overall conclusion is that it seemed

3

to be an overwhelming lack of support.

4

any type of documentation to provide validity to how the money

5

was spent, and based on our review throughout the investigation

6

we identified various wire payments going over to Africa as

7

well as other spending that would not be conducive of eligible

8

business spending for either the EIDL or PPP.
THE COURT:

9

There were no receipts,

Well, sometimes it goes without saying

10

needs to be said.

Is there anything in the EIDL or PPP

11

programs that authorizes the recipient of a loan, grant, or

12

other payment to expend the money in foreign countries?
THE WITNESS:

13

I would caveat that with it depends.

14

Primarily, it has to have a direct business correlation to the

15

business that applied.

16

there were a scenario where a U.S. based corporation possibly

17

had employees -- legitimate employees -- overseas, there could

18

be a scenario where that could be warranted.
THE COURT:

19

So, thinking outside of the box, if

Yeah, a business employee.

It doesn't

20

allow for or it doesn't even mention anywhere charitable

21

purposes in a foreign country.

22

THE WITNESS:

23

THE COURT:

24
25

That's correct.

Charitable ---

You can't run your own foreign aid

program.
THE WITNESS:

That's correct.

The EIDL or the PPP


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1

were not established to provide for a charitable benefit.
THE COURT:

2

Curiosity compels me to ask, Special Agent

3

Lott, how these lender fees are calculated.

4

hefty.

5

THE WITNESS:

Yes, sir.

They seem pretty

So the way the PPP program

6

operates is the SBA delegates authority to third-party lender

7

financial institutions --

8

THE COURT:

9

THE WITNESS:

10

THE COURT:

11

I remember.
-- in exchange -I didn't know it was like this.

You had a

$8,000 loan that had a $2,500 lender fee, did you?

12

THE WITNESS:

13

THE COURT:

14

THE WITNESS:

That's correct.
Yeah.
So throughout the period of the program

15

there were some changes as to how those lender fees were

16

calculated.

17

50 percent of the processing fee or $2,500, whichever is less,

18

for loans that were less than $50,000.

At one point in time lenders would receive

19

THE COURT:

20

THE WITNESS:

Okay.
And another point in time it was based

21

on a 5 percent calculation.

22

THE COURT:

23

Anything else, Mr. Hamner, Mr. Vines?

24

MR. HAMNER:

No, Your Honor.

25

MR. VINES:

No, Your Honor.

Okay.

Well, thank you.


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1

THE COURT:

Okay.

2

MR. HAMNER:

With regards to this objection, Your

3
4
5
6

What else, Mr. Hamner?

Honor, nothing further.
THE COURT:

Well, let me get a total on what Special

Agent Lott now -- have you got a total of all of this?
THE WITNESS:

Yes, Your Honor.

I've got a total of

7

$552,991.83 of actual loss.

If we account for the payments

8

that have been applied towards Ms. Jane Njeru's loan, that

9

brings that actual total due today of $547,095.07.

10

THE COURT:

Well, thank you very much, sir.

11

Anything else?

12

MR. VINES:

Just a small argument, Judge.

13

THE COURT:

Go ahead.

14

MR. VINES:

Thank You, Judge.

Judge, one of the

15

biggest issues that we take -- what we'd like to point out is

16

that Ms. Jane, $119,810.71 -- she's making payments.

17

received that money.

18

deduct that from what they are -- the state or the government

19

is referring to as actual loss, my calculation comes to

20

$433,181.12.

She's making that money.

She

So if you

21

THE COURT:

Is that a question to him?

22

MR. VINES:

No, Judge.

23

THE COURT:

Well, we'll take that a little later.

24

MR. VINES:

My apologies, Judge.

25

THE COURT:

Okay.

It was just argument.

I am going to give you an


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1

opportunity to go over the whole thing.

2

MR. VINES:

My apologies.

I'll sit down and shut up.

3

THE COURT:

Candidly, Special Agent Lott, the lender

4

fees really had very little, if anything, to do with checking

5

out the veracity of the application; is that correct?
THE WITNESS:

6

That's correct.

It is moreso an

7

unintended consequence I would classify it as taking out the

8

loan therefore caused the payment of those lender fees and the

9

accrued interest to the U.S. Government.
THE COURT:

10

The Congress and everybody else was not

11

blind to the fact that there was going to be some fraud.

12

was going to be all of these things and the objective was to

13

get the money out quickly and not to spend three or four months

14

looking over the application.

15

THE WITNESS:

16

THE COURT:

Okay.

17

MR. HAMNER:

No, Your Honor.

18

THE COURT:

Thank you, Special Agent Lott.

19

All right.

What else do you want to say on

20

22
23
24
25

Yes, Your Honor.

restitution, Mr. Vines?

21

All right.

Anything else, counsel?

You have the floor.

MR. VINES:

Thank you, Your Honor.

If I may have one

THE COURT:

I assume you were finished there,

moment.

Mr. Hamner?
MR. HAMNER:

There

Yes, Your Honor.

Thank you.


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1

THE COURT:

Okay.

2

MR. VINES:

Judge, against my advice my client would

3

like to take the stand.
THE COURT:

4

All right.

You want her at the lectern

5

where I can look at her or does she want to -- it depends on

6

how long she's going to be.

7

that'll be one thing.

8

THE DEFENDANT:

9

THE COURT:

If she's going to be seated,

I can stand.

All right.

Take an oath.

(Gladys Harun is duly sworn.)

10
11

THE COURT:

Go ahead, Mr. Vines.

12

MR. VINES:

Thank you, Your Honor.
DIRECT EXAMINATION

13
14

BY MR. VINES:

15

Q

Please state your name for the record.

16

A

My name is Gladys Harun.

17

Q

Ms. Harun, I want to ask you a few questions regarding

18

your --THE COURT:

19
20

Pull that microphone over closer to you,

Mr. Vines.

21

MR. VINES:

Yes, Your Honor.

22

THE COURT:

Thank you.

23

Q

Ms. Harun, I would like to ask you a couple of questions

24

regarding some of these loans.

25

April 10 loan for -- ending in 7702, $46,033 which was -- you

First, I'll begin with the


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1

received.

Could you tell us about that?

2

A

3

became a Jackson Hewitt.

4

55 employees and I applied this loan to pay for the payroll, to

5

pay for the rent, and to pay for my supplies as given by SBA.

6

Q

7

in 9010 which would be the bulk it appears of 2000 -- $299,913.

8

Could you please explain that?

9

A

10

employer I had paid in more wages than it was reported to IRS.

11

I had hired a company called Square Payroll to handle my

12

payroll.

13

contractors bonuses and the bonuses were not included in there

14

and so I called SBA and SBA give me the phone number to call

15

Lendistry and so I called Lendistry and I explained to them the

16

problems I was having and so Lendistry offered to help me get

17

enough money for me to pay for my employees and to pay for

18

everything and then when I received the money, Your Honor, I

19

paid everything to the employees.

Yes, Your Honor.

I have been an employer since 2016 when I
So I had 12 locations and I had like

I'd like to bring your attention now to the July 1 ending

That one was I applied in 2011.

I called SBA because as an

So, unfortunately, I used to pay my employees and

My total -- my total payroll for those two years was

20
21

617,000 and that's what is recorded in the IRS.

They already

22

knew I had issues with my payroll.

23

shrewd.

24

Lendistry offered to help me and they give me that money.

25

Q

I wasn't trying to be

I was trying to get money for my business and

I want to bring your attention to 8907; 20,710.

Would you


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1

mind explaining to the Court?

2

A

3

and something.

4

Q

Okay.

5

A

Yes, sir.

6

Q

Now Mr. Black ---

7

A

Jacqueline.

8

Q

I'm sorry.

9

like to tell the Court regarding that?

10

A

11

years.

12

They qualified for the money as independent contractors.

13

Independent contractors don't really have to have a business.

14

You just have to have self-employed income like if you do

15

something on the side.

16

came to my office she told me that she had a hotel or a

17

restaurant in Florida in 2018 and so she also give me her tax

18

return for 2019 that I attached and give it to SBA.

19

qualified for the money.

20

Q

To your knowledge did she receive the money?

21

A

She received the money, yes.

22

bank.

23

Q

How much of that did you receive as fees?

24

A

She came and gave me a donation of like 800.

25

have a school in Africa and I sent my father the money.

They said I qualified, also, for a grant that was 10,000
They added that one to me, too.

Ms. Jacqueline Black.

Is there anything you'd

Jacqueline Black -- I had done her taxes for like two
Everybody that I applied for I did my due diligence.

So Jacqueline Black told me -- when she

So she

She received the money in her

I told her we


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I wasn't charging them a fee, Your Honor.

1

I was just doing

2

it and then if you feel like donating anything, you bring me a

3

donation.

4

anything, that's fine.

5

Q

Okay.

6

A

Who is that?

7

Q

Well, we'll move on.

8

A

Oh, Ms. Jane.

9

She has been an independent contractor for so long and hers was

10

a lot of money and I remember she was called by SBA.

11

lady called Savannah from SBA who did her a phone interview

12

before they released the money and so Savannah, Jane Njeru --

13

they added me on the call and I spoke to lady in SBA before she

14

released the money.

15

tax returns?"

16

independent contractor as a caregiver all those years and

17

afterwards Ms. Savannah qualified her for the money.

18

my due diligence.

I even called SBA for her and there were

19

emails from SBA.

There were a lot of communications from SBA

20

and I attached also her tax returns for the previous years.

21

Q

Now how much of that money did you receive?

22

A

I think she donated like 1000 or something.

23

her for the money.

24

Q

Lastly, I want to talk about Esther Njoroge.

25

A

Esther Njoroge -- most of them were qualified for the

That's all.

Whoever didn't feel like giving me

How about Hoven?
Who was that?
Ms. Jane?

Jane was -- is an independent contractor.

It's a

She told me, "Can you explain to me her

And I explained to her that Jane was paid as an

So I did

I didn't ask

She just gave it to me.


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1

grants.

2

giving them the grants freely, but overall whoever came to me I

3

was doing their tax returns before.

4

what we call a Schedule C which is a profit and loss in their

5

taxes and that is what I was using to qualify them.

6

one and she was an independent contractor as a caregiver in the

7

state of Washington.

8

Q

Is there anything else you'd like to tell the Court?

9

A

I would like to tell the Court all the applications I did I

10

did my due diligence.

11

most all of them were independent contractors and I also was

12

calling SBA just to confirm that they really qualified for the

13

money, but SBA also qualified them for the grants.

14

ask for the grants, but the government give them the grants.

15

Q

No further questions.

16

A

Okay.

17

Q

I'm sorry.

18

Court?

19

A

20

release my EIDL loan.

21

loan I declared less money.

22

but I had made approximately 850.

23

less money because I had put less income in the application,

24

and it went to the right purposes.

25

I never applied for grants for anybody, but SBA was

I made sure that they had

Esther had

I asked them for their tax returns and

I didn't

Is there anything else you wish to address the

And even for mine I was interviewed by SBA before they

MR. VINES:

Your Honor, when I applied for that EIDL
I declared that I made $650,000,
So, basically, SBA gave me

No further questions, Your Honor.


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1

THE DEFENDANT:

2

MR. VINES:

The government will have ---

3

THE COURT:

Wait just a minute.

4

Mr. Hamner, she's under oath.

5

Thank you.

Did you want to ask her

any questions?

6

MR. HAMNER:

Just a couple, Your Honor.

7

I do it here from the table?

8

THE COURT:

Is it okay if

Sure.
CROSS EXAMINATION

9
10

BY MR. HAMNER:

11

Q

12

you received funding for; is that correct?

13

A

14

coming to an end.

15

five lenders so one of them can give me the money.

16

applied I think to five lenders, but one of them qualified me.

17

They told me not to fear, just apply.

18

money, the others will not give you money.

19

system.

20

Q

21

approximately $46,000?

22

A

Yes, sir.

23

Q

And in that application how many employees did you state

24

you had?

25

A

Ms. Harun, you applied for three PPP loans at least that

I believe I applied for more.

They told me the money was

So SBA told me to apply like a minimum of
So I

If one gives you the
They'll see in the

Did you apply for a PPP loan on April 10 that was for

I did.

I can't recall how many employees I had at that time, but I


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1

told SBA and everybody else I had errors.

2

Fargo as my payroll company and I switched to Square Payroll

3

and some of the data was lost and I was forthcoming with this

4

information to the government and to everybody else.

5

that.

6

Q

7

loans.

8

withdrew $100,000?

9

A

Yes, Your Honor.

10

Q

What did you do with that money?

11

A

It was for my attorney fees.

Okay.

I was using Wells

They knew

I am not going to ask any more questions about the

Do you recall after this investigation began that you

12

THE COURT:

13

THE WITNESS:

Yes.

I'm sorry.

For what?
Attorney fees.

It went to my first

14

attorney was Jimmy Howell.

15

Q

16

States letting you know that you were under Investigation you

17

immediately went and withdraw $100,000 from your bank account;

18

is that correct?

19

A

20

what you're supposed to do or what you're not supposed to do.

21

I wasn't doing it for malice.

22

attorney.

23

you can't withdraw money if you're under federal investigation.

24

Nobody told me about that.

25

Q

So after you received a grand jury subpoena from the United

I apologize.

Because I am not from America, I don't know

I was just drawing money for my

I wasn't doing it for anything else.

I didn't know

I didn't know that.

So you withdrew $100,000 after you got the grand jury


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1

subpoena?

2

A

Yes, I did that.

3

Q

What did you do with that $100,000?

4

A

It was for my legal fees.

5

attorney.

6

Q

7

you found out you were under investigation on May 17, 2022?

8

A

9

to my house, spends the night.

10

times in a day.

11

Q

So is --

12

A

We've been close friends.

13

Q

-- it fair to say that you made a phonecall to her after

14

you found out you were under investigation?

15

A

16

came to my house several times and spent the night.

17

children are here.

18

friends and, you know, we've been hanging out together and

19

everything.

20

Okay.

It went to my

Did you make a phonecall to Tanisha Roberson after

Tanisha Roberson has been my friend since 2011.

She comes

So we call each other like 20

I don't recall calling her that particular moment, but she

MR. HAMNER:

They can tell you.

Okay.

21

further questions.

22

THE COURT:

23

THE DEFENDANT:

24

THE COURT:

25

That's all.

My

We have been close

Your Honor, I don't have any

I don't think it's going to be productive.
Ms. Harun -Yes, Your Honor.

-- you supplied to the probation officer

a -- shall we say an effort in explanation of where the money


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1

went.

How was that money transferred?
THE DEFENDANT:

2

Did you use checks?

To the employees?

Yeah, I paid them

3

through a payroll company called Square and the government has

4

all the W-2s and the 1099s and it will total to 617,000.

5

government already has that.

6

THE COURT:

7

THE DEFENDANT:

8

THE COURT:

9

THE WITNESS:

IRS.

10

THE COURT:

The what?

11

THE DEFENDANT:

12

THE COURT:

The

Who in the government has that?
IRS.

Huh?
Internal Revenue Service.

Internal Revenue Service.

Well, when you gave this explanation to

13

probation, did you supply any backup information or any

14

checks --

15

THE DEFENDANT:

16

THE COURT:

Yes, Your Honor.

-- or indicia of payment to these

17

investigators from SBA?

18

THE DEFENDANT:

I did everything, Your Honor.

Even my

19

attorney right now has all of the W-2s.

20

payments.

21

during the investigation I remember when they called me for the

22

proffer we sent them everything, but it was a previous DA.

23

Q

They have everything.

He has all the rent

They have everything.

Even

So you have copies of everything you sent?

24

THE DEFENDANT:

25

THE COURT:

Yes, sir, I do.

And, yet, you supplied no more information


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1

than what this listing that you gave to the probation office?
THE DEFENDANT:

2

I gave my attorney a bigger stack of

3

documents.

4

Square Payroll documents.

5

probation office is missing something, but I have everything --

6

everything from Square Payroll.
THE COURT:

7
8

He has all the W-2s, all the 1099s, and all the
I don't see them there.

Maybe the

Ms. Harun, I will be candid enough to tell

you that I don't think I understood everything you said.

9

THE DEFENDANT:

10

THE COURT:

I'm sorry.

However, I believe that you said,

11

essentially, when you wrapped up your testimony that you did

12

everything in compliance with the loans and grants that you

13

applied for.

14

THE DEFENDANT:

15

THE COURT:

16
17

Yes, sir.

So you really haven't committed a crime

here?
THE DEFENDANT:

No, I didn't mean that.

I said I

18

could have made a mistake, but it was not intentional.

19

wasn't trying to rob the government or anything.

20

I did I sincerely apologize for them.

21
22
23
24
25

MR. VINES:

I

The mistakes

Your Honor, if I may approach to talk to

my client right quick.
THE COURT:

Well, I am okay if you -- always you may

consult with your client, Mr. Vines.
MR. VINES:

Thank you.


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1

Your Honor, my client would like to clarify.

2

admits her wrongdoing, Judge, but as the old saying goes, the

3

road to hell was paved with good intentions.

4

THE COURT:

5

oath and testifying.

6

MR. VINES:

Over my --

7

THE COURT:

Are you going to -- you're going to

9

MR. VINES:

Against my advice, Judge.

10

THE COURT:

I understand that, but I want to know who

11

is testifying here, Mr. Vines.

12

MR. VINES:

I'll sit down, Judge.

13

THE COURT:

All right.

14

Look, Ms. Harun, you plead guilty to an Information.

8

Am I to hear that from her?

She

She's under

Now you called her to this witness stand.

testify?

15

When you plead guilty to an Information all of the conduct

16

comes in.

17

case.

18

me how everything was actually very legitimate and you had

19

backup for all of it.

20

commit any crimes or what?

21

It doesn't matter if it is a very small part of a

I have to review every part of it.

THE DEFENDANT:

You went on telling

Now are you telling me that you didn't
Tell me what you're telling me.

The application I did for Katina

22

Wells -- I think that's what I was charged with, the one for

23

Katina Wells.

24

That's the one I took the plea for.

25

did not complete some information for Ms. Wells.

There was an application that I did for her.
Mr. Jack told me that I
That's my


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1

understanding, Your Honor.

2

THE COURT:

Okay.

3

MR. HAMNER:

No, Your Honor.

4

THE COURT:

Have a seat, Ms. Harun.

5

Mr. Vines, are there other objections that you wish to

6

Anything else, Counsel?

pursue?

7

MR. VINES:

Your Honor, I will jump over to ---

8

THE COURT:

For example, we have the item no. 2, the

9

offense level.

10

MR. VINES:

Yes, Your Honor.

11

THE COURT:

You were seeking a -- well, you'll have to

12
13

explain it to me.
MR. VINES:

Thank you, Your Honor.

Your Honor, the

14

Plea Agreement states that the U.S. Government will recommend

15

and the defendant will recommend to the Court and probation

16

that for the purposes of Section 2B1.1 of the Sentencing

17

Guidelines that it's less than $550,000.

18

offense level -- total offense level with not getting

19

acceptance and everything at an 18 instead of a 20, Your Honor.

20

It would be 14 as it is now with enhancement.

21

that according to the Plea Agreement it should be a 12.

22

researched the case law and long and short of it is it is

23

within the sole discretion of the Court whether the Court

24

accepts the Plea Agreement recommendation or not, but we're

25

asking the Court to keep the sanctity of the Plea Agreement

That would put her

We're saying
I have


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1

whole and allow her to have those two -- that two-point

2

reduction -- and that would, in effect, put her at, I believe,

3

it's 27 to 33 -- yes, Your Honor -- 27 to 33 is base level

4

offense or total offense level of 18 instead of 20 which is 33

5

to 41, Your Honor.

6

THE COURT:

Mr. Hamner, any comments on that issue?

7

MR. HAMNER:

Briefly, Your Honor.

Just that we did

8

agree in the Plea Agreement to an amount less than $550,000 and

9

that amount was based on the actual loss incurred by the SBA.

10

I understand probation's point is the intended loss was closer

11

to a million dollars.

12

calculated.

13

accordance with the Plea Agreement and it was based on the

14

actual loss, Your Honor.

15
16

I don't dispute the amounts as

Our recommendation we continue to make in

THE COURT:

And that's more than 250 but less than

MR. HAMNER:

Correct, Your Honor.

550?

17

I believe the

18

testimony today was approximately $547,000 which is in that

19

range.

20
21
22

THE COURT:

You wanted to talk about acceptance of

responsibility, also, Mr. Vines.
MR. VINES:

Is that correct?

Yes, Your Honor.

The case law is very

23

clear on that that the defense has the burden of proving that.

24

The case law says it's an uphill battle.

25

testimony that was given by my client and the totality of the

Your Honor, given the


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1

circumstances, we would rest and say that we would ask the

2

Court to give her acceptance of responsibility.
THE COURT:

3
4

MR. HAMNER:

Not on behalf of the United States, Your

THE COURT:

Mr. Vines, anything else with respect to

Honor.

7
8

Anything else with respect to

objections?

5
6

So noted.

the objections?
MR. VINES:

9

Your Honor, I would just point out

10

regarding objection number one my calculation that if the Court

11

does go with 552,991.83, we would ask the Court to deduct

12

Ms. Jane's $119,810.71 and grant restitution $433,181.12 or

13

less.

14

THE COURT:

Thank you.

With respect to the objections

15

that have been raised by counsel for Ms. Harun, paragraph 69

16

and 141, the probation officer's response is instructive.

17

so-called documentation supplied by Ms. Harun is a

18

self-serving, auto-supportive writing which has no basis or

19

support in genuine or conventionally-accepted business

20

practices.

21

can be interpreted as nothing but pretext.

22

respect to questions of how monies were spent, it may seem

23

important to Ms. Harun, but it's unimportant to the Court

24

because these loans forgivable or not or grants, EIDL, PPP or

25

otherwise were obtained generally by false pretenses, false

The

It is a bland and grossly general statement which
Moreover, with


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1

statements which is the offense to which she plead guilty.
Now the negotiated Plea Agreement does not make it,

2
3

shall we say, infinitely easy for the Court to calculate

4

because, apparently, the parties picked the lowest ranking and

5

least egregious transaction to identify as that which is

6

announced in the Information, but, of course, all relevant

7

conduct is to be considered by the Court in sentencing.

8

vehicular means of this Information were selected by the

9

parties in their independent -- their entirely independent --

10

plea negotiations for one purpose and that is to arrive at a

11

single count that would have a maximum penalty attached

12

acceptable to both sides for whatever reasons they had at the

13

moment.

The

14

The objections regarding paragraph 69 and 141 relate

15

to the amount of actual loss and the only genuinely supported

16

information before the Court is the testimony of Special Agent

17

Lott that that sum is $547,095.07.

18

below $550,000, and that is the figure that will be used in

19

calculating the actual loss and other dependent figures.

20

probation office has calculated the restitution amount or loss

21

amount at 552,679.14.

22

there.

That is above $250,000,

The

So a recalculation will be required

23

With respect to paragraph 84 and the probation

24

officer's response, I will note that it is the defendant's role

25

to support in any way she can the entitlement to a reduction in


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1

the offense level on account of acceptance of responsibility.

2

Acceptance of responsibility involves, in addition to mere

3

acknowledgment, some level of remorse, contrition or other

4

genuine manifestation or demonstration of regret.

5

here, especially with the attempt to obstruct justice in

6

tampering with witness and statements made in connection

7

therewith as reported in the probation officer's response

8

number three.

I see none

9

Accordingly, the offense level will remain at 18,

10

criminal history category I, providing for 27 to 33 months

11

imprisonment, one to three years of supervised release, 10,000

12

to $100,000 in fines, restitution in the amount of $547,095.07,

13

and a $100 special assessment.

14

of course, is a prison term of five years.

The maximum statutory penalty,

15

What was your recommendation in this case, Mr. Hamner?

16

MR. HAMNER:

The recommendation?

17

THE COURT:

With respect to sentencing.

18

to a recommendation?

19

MR. HAMNER:

20

recommendation, Your Honor.

21

THE COURT:

22

Did you agree

We agreed to a low-end guideline

I see.

And it is recommended by probation

-- I don't know if that's public or not, but it was 41 months.

23

MR. HAMNER:

I believe that was based on the ---

24

THE COURT:

Earlier guidelines.

25

Mr. Vines, Ms. Harun, I will tell you directly at this


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1

point that the Court is considering a sentence in this case of

2

anywhere from the low end of the guidelines to the maximum

3

statutory punishment.

4

sentencing.

5

requires some delay, then I will grant a period of time for you

6

to have that under consideration.

7

about that, you may also have a few moments to do that.

You're entitled to know that prior to

It is before the Court and if that in your mind

If you would like to confer

8

MR. VINES:

If I may confer, Judge.

9

THE COURT:

Say that again.

10

MR. VINES:

If I may have a few moments.

11

THE COURT:

All right.

12

MR. VINES:

Your Honor, after speaking with my client,

13

she'd like to move forward today.
THE COURT:

14

So noted.

Mr. Hamner, do you see anything

15

else that needs to be done before we go into matters of

16

allocution?
MR. HAMNER:

17

No, Your Honor.

I think we've covered

18

the amount of restitution and the guidelines that are

19

applicable.

20

Honor.

21
22

I don't believe there is anything else, Your

Thank you.
THE COURT:

Mr. Vines, is there any reason why we

should not proceed into matters of allocution?

23

MR. VINES:

24

Judge, once again, over my advice, my client is

25

Another moment, Judge.

wanting the Court -- asking the Court to revisit the issue of


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1

restitution.

I have explained to her that we've moved past

2

that matter, but she wants me to ask.

3

THE COURT:

4

to in allocution --

5

MR. VINES:

Thank you, Judge.

6

THE COURT:

-- mitigation, that sort of thing.

7

MR. VINES:

Yes, sir.

8

THE COURT:

Just because the amount of loss is

9

Well, you can bring up anything you want

established doesn't mean that has to be ordered as restitution.

10

MR. VINES:

Thank you, Judge.

11

THE COURT:

What I want to know is can we go from one

12

phase to the other now?

13
14

All right.

MR. VINES:

Is there any reason why we

No, Your Honor.

I have two to three

witnesses here, Judge, regarding sentencing.
THE COURT:

19
20

THE COURT:

should not proceed with sentencing at this time?

17
18

Judge, she's wanting to move forward

today.

15
16

MR. VINES:

All right.

Then let me proceed to say

this.
Ms. Harun, we're going into the question of sentencing

21
22

now.

23

do you have that right, I always encourage it.

24

call on you when he is ready for you to do so.

25

You have a right to make a personal statement.

All right.

Mr. Vines.

Not only

Mr. Vines will


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(Emanuel Githinji - Direct by Mr. Vines)
1

MR. VINES:

Thank you, Your Honor.

2

THE COURT:

Proceed.

3

MR. VINES:

Your Honor, At this time I would call Mr.

5

THE COURT:

Go ahead, Mr. Vines.

6

MR. VINES:

Sir, please state your name.

4

7

You have the floor.

Emanuel.

Well,

actually, raise your right hand.

8

THE COURT:

Johnny, get up here by that microphone.

9

MR. VINES:

Yes, sir.

10

THE COURT:

There you are.

(Emanuel Githinji is duly sworn by Mr. Vines)

11

DIRECT EXAMINATION

12
13

BY MR. VINES:

14

Q

15

record.

16

A

Emanuel. Emanuel Githinji.

17

Q

Could your spell your last name?

18

A

G-I-T-H-I-N-J-I.

19

Q

And, sir, what is your relationship with my client?

20

A

She's my mother.

21

Q

And how old are you, sir?

22

A

Say what?

23

Q

How old are you?

24

A

16 years old.

25

Q

Is there anything you want to tell the Court?

You got to speak up.

Please state your name for the


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(Emanuel Githinji - Direct by Mr. Vines)
1

A

2

in the house.

3

Q

Sir, you have to speak a lot louder.

4

A

We want her back home.

5

need her back.

6

Q

I'm sorry, sir.

7

A

Just we want her back home.

8

her back home.

9

Q

Has she always supported y'all?

10

A

Yes.

11

encouraging me, uplifting me like a good mother would.

12

Q

13

constant communication with y'all?

14

A

15

about everything:

16

Q

17

willing to provide support to her?

18

A

Yes, we would.

19

Q

Is there anything else you'd like the Court to know?

20

A

No.

21

Q

Thank you.

I just want to say that we need our mother home, everybody

It's been tough without her and we

Yeah, that's it.
I couldn't hear you.
Everybody -- everybody wants

She's always supported me through basketball, always

And during her 19-month incarceration has she been in

Yes, she has.

Okay.

We talk every day.

I have talked to her

Basketball, school -- you know, everything.

And while she provides support would y'all be

That's it.

22

THE COURT:

I know she appreciates your being here.

23

MR. VINES:

Wait a minute.

24
25

41

The government may have

some questions for you.
MR. HAMNER:

I have no questions for her son.


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(Ann Wangui - Direct by Mr. Vines)
MR. VINES:

1

Miss Ann.

(Ann Wangui is duly sworn by Mr. Vines)

2

DIRECT EXAMINATION

3
4

BY MR. VINES:

5

Q

Please state your name.

6

A

Ann Wangui.

7

Q

Please spell your last name.

8

A

W-A-N-G-U-I.

9

Q

And how old are you?

10

A

13 years old.

11

Q

And what is your relationship with my client?

12

A

She's my mother.

13

Q

And is there anything you'd like to tell the Court?

14

there anything you'd like to tell the Court?

15

A

16

respect.

17

back, you know.

18

Q

19

community?

20

A

Yes.

21

Q

Has she always been a viable member of the community?

22

A

Yes.

23

Q

With y'alls support do you think that she would continue to

24

be that?

25

A

A loving mother.

She's a very hard-working mother.
I look up to her like a lot.
She's very helpful.

Is

I mean, she deserves my
We really need her
Yeah.

To your knowledge has she always been helpful to the

Yes, I do.


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(Simon Juchu - Direct by Mr. Vines)
1

Q

Anything else?

2

A

No.

3

Q

Thank you.

The government may have a question.

4

MR. HAMNER:

No questions, Your Honor.

5

THE COURT:

I know she appreciates your being here

7

MR. VINES:

Mr. Simon.

8

THE WITNESS:

6

9

today.
Sir, please state your name.

My name is Simon Juchu.

My name -- last

is spelled by J-U-C-H-U.
(Simon Juchu is duly sworn by Mr. Vines)

10

DIRECT EXAMINATION

11
12

BY MR. VINES:

13

Q

Sir, what is your relationship to my client?

14

A

Say that again.

15

Q

What is your relationship to my client?

16

A

She's my cousin.

17

Q

How long have you known her?

18

A

Since childhood.

19

the U.S. and I later came and found her here.

20

Q

21

community, if you will?

22

A

23

helpful person, and very helpful person in the community.

24

made a bad choice, but that's out of her character.

25

she's very helpful even in our own community.

We grew up together.

She immigrated to

And to your knowledge has she always been a pillar of the

Yes.

To my knowledge she's been very hard-working, very
She

Overall,

I know even in


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(Simon Juchu - Direct by Mr. Vines)
1

our own company she had a program where she was helping the

2

needy to file their taxes very discounted or for free for those

3

who could not afford and I know she was doing that.

4

So she -- the family, anybody who needed help.

I know the

5

family runs a school that helps the needy and she was very

6

instrumental in organizing people here to help and supporting

7

needy kids.

8

through this experience she's going to reinvent herself.

9

has learned her mistakes and I believe that she's going to

10

reinvent herself and be a better person like she has always

11

been.

12

Q

Is there anything else you'd like to tell the Court?

13

A

I would like to tell the Court that Gladys is a very

14

dedicated mother who supports her six children.

15

one -- she was taken in when he was two.

16

is the pillar to that home and these kids like Ann here --

17

she's been doing most of the cooking for the kids and she's

18

telling me she just wants mama home.

19

that the judge will consider that as -- the honorable judge

20

will consider that as he sentences that she will be able to

21

support the community and also her children who are very

22

intelligent, smart kids and they look at her as a role model.

23

Thank you.

24
25

So she's been very helpful and I know that even

MR. VINES:

Thank you.

have a question for you.

She

The youngest

He's now three.

They need her.

She

I believe

I believe the government may


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1

MR. HAMNER:

No questions on that either, Your Honor.

2

MR. VINES:

Your Honor, I believe my client would like

3

to make a statement to the Court.

4

THE COURT:

All right.

5

MR. VINES:

If she can approach, Judge.

6

THE COURT:

Please.

7

THE DEFENDANT:

8

opportunity to address the Court.

9

coming to America.

10

take anything for granted because I came to America in 2005

11

with only $20 in my pocket.

12

in a couch for several months as I settled down in America.

13

pray to God every day to bless me and I promise God that I

14

would be a blessing to other people especially back in Kenya

15

where we don't have anything.

16

Thank you, Your Honor, for this
I'm forever grateful for

I count it a blessing every day.

I do not

I slept in my friend's living room

I grew up in a remote area in Kenya called Nyahururu

17

(phonetic).

I walked to school 2 miles each morning like all

18

the other children.

19

have a lot in our families, and most of the public schools do

20

not have any school buses and rain was not an excuse for

21

missing school and so every child had to carry their food,

22

water back to school and even today as I stand before you the

23

community struggles every day with the economy.

24

like between eight and four dollars a day.

25

programs like Medicaid, food stamps or DFACS or all those

We didn't have no vehicles.

We didn't

People make

We don't have

I


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1

things.

When I drive a car in America when I go through a

2

drive-thru, Your Honor, when I see a bus picking up my kids

3

every morning, I see -- I thank God for my blessings every day.

4

Even as I stand before you it has been a blessing for

5

me to run a business in America, to attend college, even to

6

raise a family.

7

better life than I had, you know.

8

and, sure, it has been a blessing for me to be in this country.

9

I wanted you to know that, and I founded Embrace Africa so I

10

could help seniors with taxes to reduce taxes for them.

11

done that since 2017.

12

discount between 40 and 100 if you're 65 and up.

13

my father and other people in the community where I came.

14

try to help other people because I know God has really helped

15

and blessed me, Your Honor.

I am grateful because my children are having a
They have a quality life

I have

When you come to my locations you get a
I also help
I

At the time of my arrest in 2012 I was supposed to

16
17

travel to Kenya.

18

2018 we had dug a well and the chemist had told me to try to

19

purify the water because the water was affecting the children's

20

teeth.

21

genuine interest to help other people and it wasn't my

22

intention to be here actually standing in your court.

23

We had the water project with my father.

So that was a problem.

In

So overall I started with a

I never intended to wrong anybody especially the

24

government that enabled me to be here.

I sincerely apologize

25

for mistakes done, shortcomings, and omissions that I committed


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1

to everybody and at this time -- at this point I ask that you

2

give me a chance to take care of my six children.

3

I have been doing some Bible studies when in custody.

4

I have done several through correspondence, and if you'd like

5

to -- I would like to give you the certificates -- some

6

certificates that they give to me and, you know, reading the

7

word of God every day and praying I believe has made me

8

reflect -- you know, reflect and think to myself as an

9

individual and from this time on I have made up my mind to

10

pursue peace with everybody.

11

I want to be a productive law-abiding person.

I want

12

to be a joy to my family.

13

and I want to put this behind me so I can continue to be a

14

blessing to everybody and so I apologize for all my mistakes,

15

all my -- whatever, you know.

16

I want to be a joy to my children

Me being from another country sometimes you find

17

yourself you really don't understand how to do stuff in America

18

and I found myself overwhelmed running a big business and so

19

much responsibilities without a mentor, but overall I have

20

learned from my mistakes and I'll be a better person in life.

21

I will be a better mother and a productive person.

22

hard-working mother like they have told you.

23

sustain myself and be a blessing to my community and, again, I

24

plead for your mercy.

25

I am a

I will be able to

I never intended all this to happen or anything and I


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1

apologize for all the mistakes I done and I pray that you may

2

have a place in your heart to forgive me.

3

Honor.

4

THE COURT:

Mr. Vines?

5

MR. VINES:

Thank you, Judge.

Thank you, Your

To circle back around

6

to what I expressed before, the road to hell was paved with

7

good intentions, Your Honor.

8

THE COURT:

That's what my mother always said.

9

MR. VINES:

Yes, sir.

Your Honor, she's stumbled.

10

would argue that she's fallen.

She's been now incarcerated

11

since July 5 of 2022, Your Honor.

12

incarceration she has completed the Disciple Institute.

13

received a certificate from there, several other certificates

14

from Gospel Express Evangelist Team.

15

growth.

I

During her time in
She

Your Honor, she showed

16

While in our current vernacular, if you will, she --

17

you could say that she hasn't expressed remorse or anything.

18

We would argue that it's due to a language barrier and a

19

cultural barrier.

20

entered a guilty plea, Your Honor.

21

support her.

22

move forward with her life, Your Honor, and, therefore, we

23

would ask that the Court either adopt the low end of the

24

guideline or in the alternative sentence her to 33 months, Your

25

Honor, and with regards to restitution we would ask that the

She is remorseful.

She is here.

She's

Her family is here to

She's wanting to put this matter behind her and


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1

Court order restitution in the amount of $433,181.12 or less.

2

THE COURT:

Anything else?

3

MR. VINES:

No.

4

THE COURT:

Y'all can have a seat for a moment.

5

MR. VINES:

Thank you, Your Honor.

6

THE COURT:

Mr. Hamner, my comments from the United

MR. HAMNER:

Your Honor, for the record in terms of

7
8

States?

9

our Plea Agreement I am constrained to recommend a low end of

10

the guidelines recommendation.

11

ask for a variation or departure from that, Njoroge has the

12

Court indicated that it's inclined to do so.

13

prohibited for arguing much beyond that.

14

I have not heard the defendant

So I think I am

The only thing I can argue for is the restitution

15

amount that we've calculated here in court.

16

is the correct amount as indicated by Special Agent Lott.

17

went through the facts and figures and I believe probation

18

recalculated those to the tune of approximately $547,000 which

19

is the correct calculation, and we argue that that ought to be

20

considered as restitution in the order.

21

I do believe that
We

To the extent the defendant has portrayed any language

22

barriers or concerns, I think it is prudent to put on the

23

record that she does have or at least is alleged to have a

24

doctorate degree as well as other educational degrees that

25

she's obtained while here in the United States and she's been


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1

articulate and seems to be very clear and understand the

2

entirety of the proceedings as well as the interviews in which

3

she's participated.

4

THE COURT:

5

I'll tell you when to stand up.

6

MR. VINES:

My apologies.

7

THE COURT:

I have a few things to say first.

Nothing further, Your Honor.
Thank you, Mr. Hamner.
Thank you.

In this

8

matter of the United States against Gladys Harun we have

9

explored a number of specific matters.

10

allocution of counsel and a statement in mitigation from the

11

defendant and some comments from the Assistant United States

12

Attorney.

13

restitution amount.

14

record of this proceeding and supported by the record of this

15

proceeding.

16

We have heard

I have resolved the objections and the potential
The resolution of those issues is in the

With respect to matters to which no objections were

17

filed or expressed during the hearing, I will adopt those

18

statements as the Court's own findings of fact.

19

announced the statutory penalty has a maximum of five years

20

imprisonment.

21

know that the total offense level is 18, criminal history

22

category is "I" and which would provide for 27 to 33 months

23

imprisonment, one to three years on supervised release, 10,000

24

to $100,000 in fines, restitution up to $547,095.07 with a $100

25

special assessment.

As earlier

The guidelines have already been announced.

We


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1

In this matter we have heard from the defendant,

2

Gladys Harun, throughout the proceeding but twice in an

3

extended statement.

4

because of the agreements made at an earlier time.

5

also feel constrained to mention that prior to this sentencing

6

hearing a number of matters have come before the Court.

7

two file folders which I brought here out of an abundance of

8

caution so that should some matter of earlier import come up by

9

reference I would have these available.

10

been a two-hearing criminal case where there was a simple

11

appearance for a guilty plea and then a sentencing hearing.

12

great deal more water has gone over this dam, so to speak.

13

The United States is somewhat restricted
I would

I have

This has not simply

A

We have concluded the matter with the appearance of

14

Attorney Johnny Vines who has piloted this matter through some

15

murky and irregular waters to bring it to conclusion, albeit

16

with zealous representation of his client.

17

guidance it may have, as it seemed in earlier times, foundered

18

upon some misunderstandings.

19

and it appears that Ms. Harun has retained other counsel.

20

of that aside, none of which is important, it is only proper to

21

say that Mr. Vines' appearance and handling of this case has,

22

in addition to providing an appropriate level of advocacy for

23

this defendant, brought a calming influence into the entirety

24

of the progress of this case.

25

Without this

Mr. Vines appears by appointment

Ms. Gladys Harun's statement by way of allocution

All


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telling her story in court today as it were is likely one which

2

has been rehearsed before:

3

her immigration, the story of her childhood, the hardships that

4

she began with and the successes that she found in coming to

5

America.

6

story of successes against very difficult odds, and I believe

7

those parts of Ms. Harun's story.

The story of her life, the story of

Those comments are a very interesting account, a

I have no doubts.

There began to be some comments which prompted me to

8
9

have some doubts beyond what I've developed during my review of

10

this Presentence Investigation Report.

11

frankly, when Ms. Harun with her intelligence and her ability

12

and her background and her successes in many avenues in this

13

world, in this life, and in this country -- when she tells me

14

sometimes you don't know how to do stuff in America, coming

15

from her that is a tall tale.

16

understanding, a knack, but a great deal of experience in how

17

to do stuff in America.

18

how to do the wrong stuff in America.

I will say, quite

She has developed not only an

The only problem is it's been about

Mr. Vines, bending to the needs of his client shall we

19
20

say, talks of a language and cultural barrier.

If I have to

21

comment on that, I will say that that is a somewhat ephemeral

22

barrier which is often used by Ms. Harun as a ladder or a force

23

propelling her upward in our very diverse society in this

24

country.

25

inability and her multi-cultural knowledge to her advantage in

She has used any accent or apparent linguistic


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every way.
I will be as candid and direct as I must in this

2
3

matter.

Ms. Harun has given us a self-serving,

4

ludicrously-optimistic statement of how the money was spent for

5

legitimate business purposes while the facts are more as

6

Special Agent Lott has testified.

7

some corporations, some gifted prevaricators have applied for

8

and stolen more federal money than this lady has; nevertheless,

9

for someone who sometimes you don't know how to do stuff in

10

America, for someone to apply for and obtained EIDL and PPP

11

funds well over a half million dollars, as far as her

12

capability and her ingenuity at stealing money from the

13

government from a program devised in haste by the most

14

well-intended Congress from the most benevolent sovereign on

15

earth, Ms. Harun has done about as well as anyone could do.

16

far as defrauding the United States of America, she is a

17

success story with few equal.

I know that some entities,

As

18

Now the government has its reasons for taking a plea

19

to an Information which is probably the most innocuous of all

20

of the loans or intended loans -- the KEW transaction.

21

the U.S. Attorney's business and they can recommend the low end

22

of the guidelines if they want to, but in a manner similar to

23

what I found in the Vinath Oudomsine case, I see here a pattern

24

of activity, a practiced art, if you will, in her relevant

25

conduct that shows more than an utter disregard for the

That's


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legitimate business owners and taxpayers of America.

2

virtual contempt for those entities that make all of this

3

possible, an almost vindictive effort to take as much as

4

possible and to flaunt it.

5

I see a

We spent a lot of time today worrying about the amount

6

of restitution and appropriately so, I suppose, although

7

speculation from the bench is that that really is the least of

8

anyone's concern because it's the least likely of any of our

9

possibilities here.

10

far cry from $547,000.

Some may be paid, but it'll probably be a

11

I am notorious for quoting Section '553(a).

I have

12

gone through sentencings in this court since 1979 and before

13

while I was practicing law from ultimately conventional

14

sentencing now to advisory guideline sentencing, but the one

15

thing that remains the same, the one thing that stands alone,

16

the one thing that does not change much is Section 3553(a) and

17

glaring in 3553(a) is the element of sentencing that requires

18

that a court take in account of the factor of deterrence.

19

That's what this sentencing is all about:

To deter --

20

not just to deter Ms. Harun from committing the same or similar

21

conduct again.

22

deter others who might be like-minded from committing the same

23

or similar conduct, from defrauding the United States of

24

America, from taking advantage of a well-intended Congress and

25

a benevolent sovereign by stealing as much money as possible

Who knows?

We'll see.

But the point is to


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1

while the world was in shock and horror from this Covid virus.

2

Of course, the powers of the Court's ability to deter

3

are limited here -- limited to the statutory maximum of five

4

years in prison.

5

a million for five years, let me just kind of figure that out

6

and see if that's worth it.

7

be to some.

8

should be known that when the risk is taken and when the

9

consequences are brought effectively and properly to the court

10

and when the conviction is known that the consequences will be

11

significant.

12

Some people might come in and say, well, half

It wouldn't be to me, but it might

It might be a pretty good risk to take, but it

With respect to all of the excuses and all the

13

protests of innocence that I've heard today and a virtual

14

denial of any genuine contrition of guilty conduct as I have

15

heard it, indeed, throughout this proceeding, I just don't

16

believe Ms. Harun.

17

Everything she did was calculated.

18

her benefit or for the benefit of her own individualized

19

idiosyncratic purposes -- to support charities in Kenya --

20

otherwise, perhaps, a noble objective, something really good to

21

be done with her own money, but not with money that she has

22

defrauded from Washington.

23

Everything she did was intentional.
Everything she did was for

Accordingly, it is the conclusion of the Presiding

24

Judge that a fair and proper sentence involving and including

25

the element of deterrence and the other factors of Title 18,


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United States Code, Section 3553 a must be more severe than the

2

guidelines that have been filed.

3

Ms. Harun, you and your attorney may rise.

4

Upon the foregoing and for the reasons stated the

5

defendant in this case, Gladys Harun, is committed to the

6

custody of the Bureau of Prisons for the purpose of

7

imprisonment for the term of 60 months which is the statutory

8

maximum.

9

departing from the sentencing range called for by the

10

guidelines as a variance or as a departure because the facts of

11

this case are of a kind beyond the contemplations of the

12

Sentencing Commission.

13

There will be no variance or departure.

I am

This is an extraordinary case, albeit within the

14

numbers that drive the guidelines.

15

practiced effort to defraud the United States of America at a

16

time when not only the country, the Congress, but every citizen

17

was acting from forces and influences of vulnerability

18

throughout.

19

fraudulent activity was made possible in these amounts only

20

because of that extraordinary era in our nation.

21

This is a situation of a

Society was in a very vulnerable state and this

Upon release from imprisonment the defendant is to be

22

placed on supervised release for a term of three years.

23

on supervised release this defendant is to comply with the

24

standard conditions of supervision adopted by this court and

25

the mandatory conditions required by federal law.

Those

While


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1

include, but are not limited to, urine testing, a prohibition

2

against possession of any firearm or other dangerous weapon and

3

a prohibition against the violation of any law, statute or

4

ordinance.

5

collection of a DNA sample as directed.

Further, this defendant is to cooperate in the

While on supervised release the defendant is to comply

6
7

with certain special conditions imposed by the Court.

I have

8

determined that these conditions are reasonably necessary to

9

achieve the purposes of sentencing.

10

conditions are imposed.

11

seated.

The following special

The defendant and her lawyer may be

12

Ms. Watson, would you please announce the conditions?

13

THE PROBATION OFFICER:

14

The defendant must submit to substance abuse testing

15

to determine if the defendant has used a prohibited substance.

16

The defendant must not attempt to obstruct or tamper with the

17

testing methods.

18

officer with access to any requested financial information and

19

authorize the release of any financial information.

20

probation office may share financial information with the U.S.

21

Attorney's Office.

22

charges or open additional lines of credit without the approval

23

of the probation officer.

24

more than one financial institution account or be a signer on a

25

financial institution account without the prior approval of the

Yes, Your Honor.

The defendant must provide the probation

The

The defendant must not incur new credit

The defendant shall not maintain


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probation officer.

2

penalty in accordance with the Schedule of Payment sheet of

3

this Judgment.

4

changes in economic circumstances that might affect her ability

5

to pay this financial penalty.

6

The defendant must pay the financial

The defendant must also notify the court of any

The defendant must submit her person, property, house,

7

residence, office, vehicle, papers, computers, other

8

electronic-communications or data-storage devices or media to a

9

search conducted by a United States Probation Officer.

10

to submit to a search may be grounds for revocation of release.

11

The defendant must warn any other occupants that the premises

12

may be subject to searches pursuant to this condition.

13

A curfew is imposed as a special condition of

Failure

14

supervision.

The defendant must comply with the conditions of

15

a curfew from 10 p.m. until 6 a.m. for the period of

16

supervision.

17

place of residence at all times and shall not leave except when

18

such leave is approved in advance by the probation officer.

During this time the defendant will remain at her

19

Those are the special conditions, Your Honor.

20

THE COURT:

The probation office is directed to

21

provide to the defendant a statement setting forth all of the

22

conditions to which her term of supervised release is subject.

23

Restitution is due in the amount of $552,679.14 to the United

24

States Small Business Administration.

25

wrestle at this moment with the idea of making installment

I am not going to try to


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1

payments.

I am going to suggest to the United States Attorney

2

that they without delay simply present a judgment to be entered

3

in this case against this defendant to be collected as the

4

United States Attorney may see fit at some time in the future.

5

I am more concerned about restitution; accordingly, I will not

6

impose a fine.

7

in the amount of $100.

Special assessment due and payable immediately

I am accepting the Plea Agreement for the usual

8
9

reasons.

The remaining counts of an indictment against this

10

defendant are dismissed.

11

custody of the United States Marshal.

This defendant is remanded to the

12

This defendant has waived any right to appeal except

13

with respect to the imposition of the sentence in this case at

14

the statutory maximum which is above the sentencing guidelines

15

found by the court in this case.

16

Now that sentence has been imposed, other than

17

objections earlier stated in the record are there any

18

objections to the Court's findings of fact, conclusions of law

19

or the manner in which sentence was imposed?

20

MR. HAMNER:

Not from the United States, Your Honor.

21

MR. VINES:

No, Your Honor.

22

THE COURT:

All right.

23

Mr. Hamner, you understood my

comments about getting a judgment?

24

MR. HAMNER:

Yes, Your Honor.

25

THE COURT:

Talk to your financial people.

I don't


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1

think it needs to wait any longer, quite frankly, than the

2

Judgment and Commitment Order.

3

MR. HAMNER:

It ought to be done this week, Your

5

THE COURT:

All right.

6

Counsel, I thank you for your patience today.

4

7

Honor.

concludes the matter.

Thank you very much.

You're free to go.

8

MR. VINES:

Thank you, Your Honor.

9

THE COURT:

The defendant is remanded.

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(The hearing is concluded.)

That


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CERTIFICATE OF REPORTER

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2
3
4
5

I, Lisa H. Davenport, Federal Official Reporter, in and

6

for the United States District Court for the Southern District

7

of Georgia, do hereby certify that pursuant to Section 753,

8

Title 28, United States Code that the foregoing is a true and

9

correct transcript of the stenographically-reported proceedings

10

held and that the transcript page format is in conformance with

11

the regulations of the Judicial Conference of the United

12

States.

14

Digitally signed by
Lisa Davenport
Date: 2024.10.17
15:24:50 -04'00'
________________________________

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Lisa H Davenport, RPR, FCRR

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Federal Official Reporter

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