Plea Agreement — United States v. Bridgitte Keim (M.D. Fla.)

Record facts

U.S. District Court, Middle District of Florida · No. 8:21-cr-00370 · Doc. 5 · 2021-12-01 · Docket on CourtListener

Full text

UNITED STATES DISTRICT COURT
MIDDLE DISTRICT OF FLORIDA
TAMPA DIVISION

UNITED STATES OF AMERICA

Vv. CASE NO. 8:21-cr-370-CEH-JSS

BRIDGITTE KEIM

PLEA AGREEMENT
Pursuant to Fed. R. Crim. P. 11(c), the United States of America, by Karin
Hoppmann, Acting United States Attorney for the Middle District of Florida, and
the defendant, Bridgitte Keim, and the attorney for the defendant, Joseph A.
Caimano, Jr., Esq., mutually agree as follows:

A. Particularized Terms

1. Count Pleading To

The defendant shall enter a plea of guilty to Count One of the
Information. Count One charges the defendant with bank fraud, in violation of
18 U.S.C. § 1344.

2. Maximum Penalties

Count One carries a maximum sentence of 30 years’ imprisonment, a
fine of $1,000,000, a term of supervised release of 5 years, and a special assessment
of $100 per felony count for individuals. With respect to certain offenses, the Court

shall order the defendant to make restitution to any victim of the offense, and with

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respect to other offenses, the Court may order the defendant to make restitution to
any victim of the offense, or to the community, as set forth below.

3. Elements of the Offense

The defendant acknowledges understanding the nature and elements of
the offense with which defendant has been charged and to which defendant is
pleading guilty. The elements of Count One are:

First: the defendant knowingly carried out or attempted to carry
out a scheme to defraud a financial institution or to get
money, assets, or other property from a financial
institution by using false or fraudulent pretenses,
representations, or promises about a material fact;

Second: the false or fraudulent pretenses, representations, or
promises were material;

Third: the defendant intended to defraud the financial institution,
and
Fourth: the financial institution was federally insured.
A. Indictment Waiver

Defendant will waive the right to be charged by way of indictment
before a federal grand jury.

5. No Further Charges

If the Court accepts this plea agreement, the United States Attorney’s
Office for the Middle District of Florida agrees not to charge defendant with
committing any other federal criminal offenses known to the United States
Attorney’s Office at the time of the execution of this agreement, related to the

conduct giving rise to this plea agreement.

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6. Mandatory Restitution to Victim of Offense of Conviction

Pursuant to 18 U.S.C. § 2327, the defendant agrees to make full
restitution to Centennial Bank and the U.S. Small Business Administration.

7, Guidelines Sentence

Pursuant to Fed. R. Crim. P. 11(c)(1)(B), the United States will
recommend to the Court that the defendant be sentenced within the defendant’s
applicable guidelines range as determined by the Court pursuant to the United States
Sentencing Guidelines, as adjusted by any departure the United States has agreed to
recommend in this plea agreement. The parties understand that such a
recommendation is not binding on the Court and that, if it is not accepted by this
Court, neither the United States nor the defendant will be allowed to withdraw from
the plea agreement, and the defendant will not be allowed to withdraw from the plea
of guilty.

8. Acceptance of Responsibility—Three Levels

At the time of sentencing and, in the event that no adverse information
is received suggesting such a recommendation to be unwarranted, the United States
will not oppose the defendant’s request to the Court that the defendant receive a two-
level downward adjustment for acceptance of responsibility, pursuant to USSG
§3E1.1(a). The defendant understands that this recommendation or request is not
binding on the Court, and if not accepted by the Court, the defendant will not be

allowed to withdraw from the plea.

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Further, at the time of sentencing, if the defendant’s offense level prior
to operation of subsection (a) is level 16 or greater, and if the defendant complies
with the provisions of USSG §3E1.1(b) and all terms of this Plea Agreement,
including but not limited to, the timely submission of the financial affidavit
referenced in Paragraph B.5., the United States agrees to file a motion pursuant to
USSG §3E1.1(b) for a downward adjustment of one additional level. The defendant
understands that the determination as to whether the defendant has qualified for a
downward adjustment of a third level for acceptance of responsibility rests solely
with the United States Attorney for the Middle District of Florida, and the defendant
agrees that the defendant cannot and will not challenge that determination, whether
by appeal, collateral attack, or otherwise.

9. Low End

At the time of sentencing, and in the event that no adverse information
is received suggesting such a recommendation to be unwarranted, the United States
will not oppose the defendant’s request to the Court that the defendant receive a
sentence at the low end of the applicable guideline range, as calculated by the Court.
The defendant understands that this recommendation or request is not binding on

the Court, and if not accepted by the Court, the defendant will not be allowed to

withdraw from the plea.

10. Cooperation—Substantial Assistance to be Considered

Defendant agrees to cooperate fully with the United States in the

investigation and prosecution of other persons, and to testify, subject to a prosecution

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for perjury or making a false statement, fully and truthfully before any federal court
proceeding or federal grand jury in connection with the charges in this case and other
matters, such cooperation to further include a full and complete disclosure of all
relevant information, including production of any and all books, papers, documents,
and other objects in defendant’s possession or control, and to be reasonably available
for interviews which the United States may require. If the cooperation is completed
prior to sentencing, the government agrees to consider whether such cooperation
qualifies as “substantial assistance” in accordance with the policy of the United
States Attorney for the Middle District of Florida, warranting the filing of a motion
at the time of sentencing recommending (1) a downward departure from the
applicable guideline range pursuant to USSG §5K1.1, or (2) the imposition of a
sentence below a statutory minimum, if any, pursuant to 18 U.S.C. § 3553(e), or (3)
both. If the cooperation is completed subsequent to sentencing, the government
agrees to consider whether such cooperation qualifies as “substantial assistance” in
accordance with the policy of the United States Attorney for the Middle District of
Florida, warranting the filing of a motion for a reduction of sentence within one year
of the imposition of sentence pursuant to Fed. R. Crim. P. 35(b). In any case, the
defendant understands that the determination as to whether “substantial assistance”
has been provided or what type of motion related thereto will be filed, if any, rests
solely with the United States Attorney for the Middle District of Florida, and the
defendant agrees that defendant cannot and will not challenge that determination,

whether by appeal, collateral attack, or otherwise.

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11. Cooperation—Responsibilities of Parties

a. The government will make known to the Court and other
relevant authorities the nature and extent of defendant’s cooperation and any other
mitigating circumstances indicative of the defendant’s rehabilitative intent by
assuming the fundamental civic duty of reporting crime. However, the defendant
understands that the government can make no representation that the Court will
impose a lesser sentence solely on account of, or in consideration of, such
cooperation.

b. It is understood that should the defendant knowingly provide
incomplete or untruthful testimony, statements, or information pursuant to this
agreement, or should the defendant falsely implicate or incriminate any person, or
should the defendant fail to voluntarily and unreservedly disclose and provide full,
complete, truthful, and honest knowledge, information, and cooperation regarding
any of the matters noted herein, the following conditions shall apply:

(1) The defendant may be prosecuted for any perjury or false
declarations, if any, committed while testifying pursuant to this agreement, or for

obstruction of justice.

(2) The United States may prosecute the defendant for the
charges which are to be dismissed pursuant to this agreement, if any, and may either
seek reinstatement of or refile such charges and prosecute the defendant thereon in
the event such charges have been dismissed pursuant to this agreement. With regard

to such charges, if any, which have been dismissed, the defendant, being fully aware

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of the nature of all such charges now pending in the instant case, and being further
aware of defendant’s rights, as to all felony charges pending in such cases (those
offenses punishable by imprisonment for a term of over one year), to not be held to
answer to said felony charges unless on a presentment or indictment of a grand jury,
and further being aware that all such felony charges in the instant case have
heretofore properly been returned by the indictment of a grand jury, does hereby
agree to reinstatement of such charges by recision of any order dismissing them or,
alternatively, does hereby waive, in open court, prosecution by indictment and
consents that the United States may proceed by information instead of by indictment
with regard to any felony charges which may be dismissed in the instant case,
pursuant to this plea agreement, and the defendant further agrees to waive the statute
of limitations and any speedy trial claims on such charges.

(3) The United States may prosecute the defendant for any
offenses set forth herein, if any, the prosecution of which in accordance with this
agreement, the United States agrees to forego, and the defendant agrees to waive the
statute of limitations and any speedy trial claims as to any such offenses.

(4) The government may use against the defendant the
defendant’s own admissions and statements and the information and books, papers,
documents, and objects that the defendant has furnished in the course of the
defendant’s cooperation with the government.

(5) The defendant will not be permitted to withdraw the guilty

pleas to those counts to which defendant hereby agrees to plead in the instant case

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but, in that event, defendant will be entitled to the sentencing limitations, if any, set
forth in this plea agreement, with regard to those counts to which the defendant has
pled; or in the alternative, at the option of the United States, the United States may
move the Court to declare this entire plea agreement null and void.

12. Forfeiture of Assets

The defendant agrees to forfeit to the United States immediately and
voluntarily any and all assets and property, or portions thereof, subject to forfeiture,
pursuant to 18 U.S.C. § 982(a)(2)(A), whether in the possession or control of the
United States, the defendant or defendant’s nominees. The assets to be forfeited
specifically include, but are not limited to, the $7500 in proceeds the defendant
admits she obtained, as the result of the commission of the offense to which the
defendant is pleading guilty. The defendant acknowledges and agrees that: (1) the
defendant obtained this amount as a result of the commission of the offense, and (2)
as a result of the acts and omissions of the defendant, the proceeds have been
transferred to third parties and cannot be located by the United States upon the
exercise of due diligence. Therefore, the defendant agrees that, pursuant to 21 U5 0.
§ 853(p), the United States is entitled to forfeit any other property of the defendant
(substitute assets), up to the amount of proceeds the defendant obtained, as the result
of the offense of conviction. The defendant further consents to, and agrees not to
oppose, any motion for substitute assets filed by the United States up to the amount
of proceeds obtained from commission of the offense and consents to the entry of the

forfeiture order into the Treasury Offset Program. The defendant agrees that

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forfeiture of substitute assets as authorized herein shall not be deemed an alteration
of the defendant’s sentence.

The defendant additionally agrees that since the criminal proceeds have
been transferred to third parties and cannot be located by the United States upon the
exercise of due diligence, the preliminary and final orders of forfeiture should
authorize the United States Attorney’s Office to conduct discovery (including
depositions, interrogatories, requests for production of documents, and the issuance
of subpoenas), pursuant to Rule 32.2(b)(3) of the F ederal Rules of Criminal
Procedure, to help identify, locate, and forfeit substitute assets.

The defendant also agrees to waive all constitutional, statutory, and
procedural challenges (including direct appeal, habeas corpus, or any other means) to
any forfeiture carried out in accordance with this Plea Agreement on any grounds,
including that the forfeiture described herein constitutes an excessive fine, was not
properly noticed in the charging instrument, addressed by the Court at the time of
the guilty plea, announced at sentencing, or incorporated into the judgment.

The defendant admits and agrees that the conduct described in the
Factual Basis below provides a sufficient factual and statutory basis for the forfeiture
of the property sought by the government. Pursuant to Rule 32.2(b)(4), the defendant
agrees that the preliminary order of forfeiture will satisfy the notice requirement and
will be final as to the defendant at the time it is entered. In the event the forfeiture is
omitted from the judgment, the defendant agrees that the forfeiture order may be

incorporated into the written judgment at any time pursuant to Rule 36.

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The defendant agrees to take all steps necessary to identify and locate
all substitute assets and to transfer custody of such assets to the United States before
the defendant’s sentencing. To that end, the defendant agrees to make a full and
complete disclosure of all assets over which defendant exercises control, including all
assets held by nominees, to execute any documents requested by the United States to
obtain from any other parties by lawful means any records of assets owned by the
defendant, and to consent to the release of the defendant’s tax returns for the
previous five years. The defendant agrees to be interviewed by the government, prior
to and after sentencing, regarding such assets. The defendant further agrees to be
polygraphed on the issue of assets, if it is deemed necessary by the United States. The
defendant agrees that Federal Rule of Criminal Procedure 11 and USSG §1B1.8 will
not protect from forfeiture assets disclosed by the defendant as part of the defendant’s
cooperation.

The defendant agrees to take all steps necessary to assist the
government in obtaining clear title to any substitute assets before the defendant’s
sentencing. In addition to providing full and complete information about substitute
assets, these steps include, but are not limited to, the surrender of title, the signing of
a consent decree of forfeiture, and signing of any other documents necessary to
effectuate such transfers.

Forfeiture of the defendant’s assets shall not be treated as satisfaction of
any fine, restitution, cost of imprisonment, or any other penalty the Court may

impose upon the defendant in addition to forfeiture.

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The defendant agrees that, in the event the Court determines that the
defendant has breached this section of the Plea Agreement, the defendant may be
found ineligible for a reduction in the Guidelines calculation for acceptance of
responsibility and substantial assistance and may be eligible for an obstruction of
justice enhancement.

The defendant agrees that the forfeiture provisions of this plea
agreement are intended to, and will, survive the defendant, notwithstanding the
abatement of any underlying criminal conviction after the execution of this
agreement. The forfeitability of any particular property pursuant to this agreement
shall be determined as if the defendant had survived, and that determination shall be
binding upon defendant’s heirs, successors and assigns until the agreed forfeiture,
including the forfeiture of any substitute assets, is final.

B. Standard Terms and Conditions

1. Restitution, Special Assessment and Fine

The defendant understands and agrees that the Court, in addition to or
in lieu of any other penalty, shall order the defendant to make restitution to any
victim of the offense, pursuant to 18 U.S.C. § 3663A, for all offenses described in 18
U.S.C. § 3663A(c)(1); and the Court may order the defendant to make restitution to
any victim of the offense, pursuant to 18 U'S.C. § 3663, including restitution as to all
counts charged, whether or not the defendant enters a plea of guilty to such counts,
and whether or not such counts are dismissed pursuant to this agreement. The

defendant further understands that compliance with any restitution payment plan

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imposed by the Court in no way precludes the United States from simultaneously
pursuing other statutory remedies for collecting restitution (28 U.S.C. § 3003(b)(2)),
including, but not limited to, garnishment and execution, pursuant to the Mandatory
Victims Restitution Act, in order to ensure that the defendant=s restitution obligation
is satisfied.

On each count to which a plea of guilty is entered, the Court shall
impose a special assessment pursuant to 18 U.S.C. § 3013. To ensure that this
obligation is satisfied, the Defendant agrees to deliver a cashier’s check, certified
check or money order to the Clerk of the Court in the amount of $100, payable to
“Clerk, U.S. District Court” within ten days of the change of plea hearing.

The defendant understands that this agreement imposes no limitation as

to fine.

2. Supervised Release

The defendant understands that the offense to which the defendant is
pleading provides for imposition of a term of supervised release upon release from
imprisonment, and that, if the defendant should violate the conditions of release, the
defendant would be subject to a further term of imprisonment.

hs Immigration Consequences of Pleading Guilty

The defendant has been advised and understands that, upon conviction,
a defendant who is not a United States citizen may be removed from the United

States, denied citizenship, and denied admission to the United States in the future.

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4. Sentencing Information

The United States reserves its right and obligation to report to the Court
and the United States Probation Office all information concerning the background,
character, and conduct of the defendant, to provide relevant factual information,
including the totality of the defendant’s criminal activities, if any, not limited to the
count to which defendant pleads, to respond to comments made by the defendant or
defendant’s counsel, and to correct any misstatements or inaccuracies. The United
States further reserves its right to make any recommendations it deems appropriate
regarding the disposition of this case, subject to any limitations set forth herein, if
any.

5. Financial Disclosures

Pursuant to 18 U.S.C. § 3664(d)(3) and Fed. R. Crim. P. 32(d)(2)(A)(@i),
the defendant agrees to complete and submit to the United States Attorney’s Office
within 30 days of execution of this agreement an affidavit reflecting the defendant’s
financial condition. The defendant promises that her financial statement and
disclosures will be complete, accurate and truthful and will include all assets in
which she has any interest or over which the defendant exercises control, directly or
indirectly, including those held by a spouse, dependent, nominee or other third party.
The defendant further agrees to execute any documents requested by the United
States needed to obtain from any third parties any records of assets owned by the
defendant, directly or through a nominee, and, by the execution of this Plea

Agreement, consents to the release of the defendant’s tax returns for the previous five

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years. The defendant similarly agrees and authorizes the United States Attorney’s
Office to provide to, and obtain from, the United States Probation Office, the
financial affidavit, any of the defendant’s federal, state, and local tax returns, bank
records and any other financial information concerning the defendant, for the
purpose of making any recommendations to the Court and for collecting any
assessments, fines, restitution, or forfeiture ordered by the Court. The defendant
expressly authorizes the United States Attorney’s Office to obtain current credit
reports in order to evaluate the defendant’s ability to satisfy any financial obligation
imposed by the Court.

6. Sentencing Recommendations

It is understood by the parties that the Court is neither a party to nor

bound by this agreement. The Court may accept or reject the agreement or defer a
decision until it has had an opportunity to consider the presentence report prepared
by the United States Probation Office. The defendant understands and acknowledges
that, although the parties are permitted to make recommendations and present
arguments to the Court, the sentence will be determined solely by the Court, with the
assistance of the United States Probation Office. Defendant further understands and
acknowledges that any discussions between defendant or defendant’s attorney and
the attorney or other agents for the government regarding any recommendations by
the government are not binding on the Court and that, should any recommendations
be rejected, defendant will not be permitted to withdraw defendant’s plea pursuant to

this plea agreement. The government expressly reserves the right to support and

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defend any decision that the Court may make with regard to the defendant’s
sentence, whether or not such decision is consistent with the government’s
recommendations contained herein.
d Defendant’s Waiver of Right to Appeal the Sentence

The defendant agrees that this Court has jurisdiction and authority to
impose any sentence up to the statutory maximum and expressly waives the right to
appeal defendant’s sentence on any ground, including the ground that the Court
erred in determining the applicable guidelines range pursuant to the United States
Sentencing Guidelines, except (a) the ground that the sentence exceeds the
defendant’s applicable guidelines range as determined by the Court pursuant to the
United States Sentencing Guidelines; (b) the ground that the sentence exceeds the
statutory maximum penalty; or (c) the ground that the sentence violates the Eighth
Amendment to the Constitution; provided, however, that if the government exercises
its right to appeal the sentence imposed, as authorized by 18 U.S.C. § 3742(b), then
the defendant is released from his waiver and may appeal the sentence as authorized
by 18 U.S.C. § 3742(a).

8. Middle District of Florida Agreement

It-is further understood that this agreement is limited to the Office of the
United States Attorney for the Middle District of Florida and cannot bind other
federal, state, or local prosecuting authorities, although this office will bring

defendant’s cooperation, if any, to the attention of other prosecuting officers or

others, if requested.

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9. Filing of Agreement

This agreement shall be presented to the Court, in open court or in
camera, in whole or in part, upon a showing of good cause, and filed in this cause, at
the time of defendant’s entry of a plea of guilty pursuant hereto.

10.  Voluntariness

The defendant acknowledges that defendant is entering into this
agreement and is pleading guilty freely and voluntarily without reliance upon any
discussions between the attorney for the government and the defendant and
defendant’s attorney and without promise of benefit of any kind (other than the
concessions contained herein), and without threats, force, intimidation, or coercion
of any kind. The defendant further acknowledges defendant’s understanding of the
nature of the offense or offenses to which defendant is pleading guilty and the
elements thereof, including the penalties provided by law, and defendant’s complete
satisfaction with the representation and advice received from defendant's
undersigned counsel (if any). The defendant also understands that defendant has the
right to plead not guilty or to persist in that plea if it has already been made, and that
defendant has the right to be tried by a jury with the assistance of counsel, the right
to confront and cross-examine the witnesses against defendant, the right against
compulsory self-incrimination, and the right to compulsory process for the
attendance of witnesses to testify in defendant’s defense; but, by pleading guilty,
defendant waives or gives up those rights and there will be no trial. The defendant

further understands that if defendant pleads guilty, the Court may ask defendant

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questions about the offense or offenses to which defendant pleaded, and if defendant
answers those questions under oath, on the record, and in the presence of counsel (if
any), defendant’s answers may later be used against defendant in a prosecution for
perjury or false statement. The defendant also understands that defendant will be
adjudicated guilty of the offenses to which defendant has pleaded and, if any of such
offenses are felonies, may thereby be deprived of certain rights, such as the right to
vote, to hold public office, to serve on a jury, or to have possession of firearms.
11. Factual Basis

Defendant is pleading guilty because defendant is in fact guilty. The
defendant certifies that defendant does hereby admit that the facts set forth below are
true, and were this case to go to trial, the United States would be able to prove those
specific facts and others beyond a reasonable doubt.

FACTS

The United States Small Business Administration (“SBA”) was an
executive-branch agency of the United States government that provided support to
entrepreneurs and small businesses. The mission of the SBA was to maintain and
strengthen the nation’s economy by enabling the establishment and viability of small
businesses and by assisting in the economic recovery of communities after disasters.
As part of this effort, the SBA enabled and provided for loans through banks, credit
unions, and other lenders. These loans had government-backed guarantees.

The Coronavirus Aid, Relief, and Economic Security (“CARES”) Act

was a federal law enacted in or around March 2020 designed to provide emergency

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financial assistance to the millions of Americans who were suffering the economic
effects caused by the COVID-19 pandemic. One source of relief provided by the
CARES Act was the authorization of forgivable loans to small businesses for job
retention and certain other expenses, through a program referred to as the Paycheck
Protection Program (“PPP”).

To obtain a PPP loan, a qualifying business was required to submit a
PPP loan aplication, which was signed by an authorized representative of the
business. The PPP loan application required the business (through its authorized
representative) to acknowledge the program rules and make certain affirmative
certifications in order to be eligible to obtain the PPP loan. In the PPP loan
application (SBA Form 2483), the small business (through its authorized
representative) was required to state, among other things, its: (a) average monthly
payroll expenses; and (b) number of employees. These figures were used to calculate
the amount of money the small business was eligible to receive under the PPP. In
addition, businesses applying for a PPP loan were required to provide
documentation showing their payroll expenses.

PPP loan applications were processed by a participating lender. Ifa
PPP loan application was approved, the participating lender funded the PPP loan
using its own monies, which were 100% guaranteed by the SBA. Data from the
application, including information from the borrower, the total amount of the loan,

and the listed number of employees, was transmitted by the lender to the SBA in the

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course of processing the loan. PPP loan proceeds were required to be used for certain
permissible expenses, including payroll costs, mortgage interest, rent, and utilities.

Bank 1 was a financial institution federally insured by the Federal
Deposit Insurance Corporation (“FDIC”) headquartered and with branches in the
Middle District of Florida and elsewhere. Bank | participated in the SBA’s PPP as a
lender and, as such, was authorized to lend funds to eligible borrowers under the
terms of PPP.

From at least in or around April 2021 and continuing through July
2021, Bridgitte Keim (hereinafter “KEIM”), knowingly and intentionally engaged in
a scheme to defraud the SBA and financial institutions by obtaining money under the
control of Bank 1 by fraudulent pretenses. Bank 1 Union 1 was a financial
institution, and its accounts and deposits were insured by the Federal Deposit
Insurance Corporation.

Keim’s role in the bank fraud scheme included the following:

a. KEIM recruited family members and friends to participate
in the SBA PPP loan program;

b. KEIM told her family members and friends that she would
prepare all necessary PPP loan paperwork knowing full well that the vast majority of
the applicants did not have existing businesses;

c. KEIM created fictitious businesses for the individuals she

recruited in order for the applicants to purportedly qualify for SBA guaranteed PPP

loans at Bank 1;

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d. KEIM created email addresses for the applicants she
recruited for the purpose of submitting PPP documents to Bank 1 and
communicating with Bank 1 loan officers to give the false appearance to the loan
officers that they were communicating with the actual prospective borrower, not
KEIM;

é. KEIM prepared and submitted to Bank 1 fraudulent PPP
loan applications and supporting financial information on behalf of relatives or
friends containing material false, fraudulent, and misleading statements in order to
qualify the individuals she recruited;

f. KEIM made material false, fraudulent, and misleading
statements to Bank 1 and SBA related to the use of the PPP funds in multiple PPP
loan application she submitted on behalf of her relatives;

g. KEIM sent text messages containing the names of the
fictitious businesses, false financial information, and the email addresses she created
to the relatives she recruited so that these individuals could answer any questions
from bank employees about the loan applications; and

a. KEIM used the PPP funds for unauthorized purposes and
for her own personal enrichment.

For example, in the Middle District of Florida, KEIM recruited her
relative, G.H., at a family meeting to participate in her bank fraud scheme. KEIM
told G.H. and other relatives she would handle all of the paperwork to file for

“COVID money,” and in return KEIM would get half of whatever money G.H.

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qualified for. At the family meeting, KEIM obtained G.H.’s and other relatives
names, dates of birth, drivers’ licenses and social security numbers. On or about
March 2, 2021, KEIM submitted a PPP loan application in the name of G.H.,
containing a fictitious business name, fictitious number of employees, falsified
business income and falsely stating that the PPP loan funds would be used for
payroll. Based on KEIM’s materially false statements, Bank 1 approved and funded a
$20,833.00 PPP loan in the name of G.H. On March 25, 2021, KEIM diverted
$7,500 in G.H.’s PPP loan proceeds to her personal account at Bank 1.

The intended losses to Bank 1 and the SBA associated with KEIM’s
criminal conduct were at least approximately $588,693.14.

12. Entire Agreement

This plea agreement constitutes the entire agreement between the
government and the defendant with respect to the aforementioned guilty plea and no
other promises, agreements, or representations exist or have been made to the

defendant or defendant’s attorney with regard to such guilty plea.

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13. Certification
The defendant and defendant’s counsel certify that this plea agreement
has been read in its entirety by (or has been read to) the defendant and that defendant

fully understands its aS 0M

DATED this / 9 An day of Novew b Fons,

KARIN HOPPMANN
Acting United States Attorney

Syn

“Bridgitte Keim
mNy Special Assistant United States Attorney
hyd jLebuellenllt.
Joseph A. cua Jr., Esq. ay G. Trezevant
Attorney fi Cpa) Assistant United States Attorney

Chief, Economic Crimes Section

22

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