Plea Agreement — United States v. Roody Metelus (S.D. Fla.)

Record facts

U.S. District Court, Southern District of Florida · No. 0:26-cr-60019-RKA · Doc. 23 · 2026-04-27 · Docket on CourtListener

Full text

UNITED STATES DISTRICT COURT
SOUTH ERN DISTRICT OF FLORIDA
CASE NO. 2& CR-60019-ALTM AN
UNITED STATES OF AM ERICA
VS.
ROODY M ETELUS,
Defendant.
/
PLEA A GREEM ENT
The United States of Ameiica and the Defendant, ROODY METELUS, (hereinafter
referred to as trefendant'), enter into the following agreement:
1. 
Defendant agrees to plead guilty to the Inform ation, which charges the Defendant
with one count of conspiracy to com mit wire fraud, in violation of Title 18, United States Code,
Section 371.
Defendant is aware that the sentence will be imposed by the Court after considering
the advisoly Federal Sentencing Guidelines and Policy Statements(hereinafter ûlsentencing
Guidelines'). Defendant acknowledges and understands that the Court will compute an advisory
sentence tmder the Sentencing Guidelines and that the applicable guidelines will be detennined by
the Court relying in part on the results of a pre-sentence investigation by the Court's probation
office, which investigation will comm ence after the guilty plea has been entered. Defendant is also
aw are that, under certain circum stances, the Court m ay depart from  the advisory sentencing
guideline range that it has com puted, and may raise or lower that advisoly sentence under the
Sentencing Guidelines. Defendant is ftzrther aware and understands that the Court is required to
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consider the advisory guideline range determined under the Sentencing Guidelines, but is not
bound to impose a sentence within that advisory range; the Court is permitted to tailor the ultimate
sentence in light of other statutory concerns, and such sentence m ay be either m ore severe or less
severe than the Sentencing Guidelines' advisory range. Knowing these facts, Defendant
understands and acknowledges that the Court has the authority to impose any sentence within and
up to the statutory m axim um authorized by 1aw for the offense identified in paragraph 1 and that
Defendant may not withdraw the plea solely as a result of the sentence imposed.
Defendant tmderstands and acknowledges that the Court may impose a statutory
maximum term of imprisonment of up to five (5) years, followed by a term of supervised release
of up to 3 years. ln addition to a tenn of imprisonm ent and supervised release, the Court may
impose a maximum fine of up to $250,000, as well as restitution and criminal forfeiture.
Defendant further tmderstands and acknowledges that, in addition to any sentence
imposed under paragraph 3 of this agreement, a special assessment in the amotmt of $100 will be
imposed on Defendant. Defendant agrees that any special assessm ent imposed shall be paid at
the tim e of sentencing.
The Oftice of the United States Attorney for the Southem  District of Florida
(hereinafter Eçoftice''l reserves the right to infonn the Court and the probation office of all facts
pertinent to the sentencing process, including all relevant inform ation concerning the offense
com mitted, whether charged or not, as well as concem ing Defendant and Defendant's background.
Subject only to the express terms of any agreed-upon sentencing recommendations contained in
this agreem ent, the Office further reserves the right to m ake any recomm endation as to the quality
and quantity of ptm ishm ent.
2
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The Office agrees that it will recomm end at sentencing that the Court reduce by
two levels the sentencing guideline level applicable to Defendant's offense, pursuant to Section
3E1. 1(a) of the Sentencing Guidelines, based upon Defendant's recognition and affinnative and
tim ely acceptance of personal responsibility. lf at the tim e of sentencing Defendant's offense
level is determined to be 16 or greater, the Oftice will file a m otion requesting an additional one
level decrease pursuant to Section 3E1.1(b) of the Sentencing Guidelines, stating that Defendant
has assisted authorities in the investigation or prosecution of Defendant's own misconduct by
tim ely notifying authorities of Defendant's intention to enter a plea of guilty, thereby permitting
the govermnent to avoid preparing for trial and permitting the governm ent and the Court to allocate
their resources efficiently. 
The Office, however, will not be required to m ake these
recommendations if Defendant: (1) fails or refuses to make a full, acclzrate and complete disclosure
to the probation office of the circumstances surrounding the relevant offense conduct; (2) is fotmd
to have m isrepresented facts to the government prior to or after entering into this plea agreement;
or (3) commits any misconduct after entering into this plea agreement, including but not limited
to comm itting a state or federal offense, violating any term of release, or m aking false statem ents
or m isrepresentations to any governm ental entity or official.
The Oftice and Defendant agree that, although not binding on the probation oftice
or the Court, they will jointly recommend that the Court make the following findings as to the
sentence to be im posed:
a. 
lntended Loss: For purposes of Section 28 1. 1, the intended loss amount,
attributable to this Defendant, is greater than $3,500,000 and less than $9,500,000,
resulting in an increase of 18 levels from the base offense level.
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b.
sophisticated meansenhancement, set forth under Section 28 1.1(b)(10) of the
The Office agrees to take no position on the applicability of the
Sentencing Guidelines.
8. 
Defendant is aware that the sentence has not yet been determ ined by the Court.
Defendant also is aware that any estimate of the probable sentencing range or sentence that the
Defendant m ay receive, whether that estim ate com es from  Defendant's attorney, the Oftice, or the
probation oftice, is a prediction, not a prom ise, and is not binding on the Oftice, the probation
office or the Court. Defendant understands further that any recom mendation that the Oftice make
to the Court as to sentencing, whether pursuant to this agreement or othenvise, is not binding on
the Court and the Court m ay disregard the recomm endation in its entirety. Defendant understands
and acknowledges, as previously acknowledged in Paragraph 2 above, that Defendant m ay not
withdraw his plea based upon the Court's decision not to accept a sentencing recom mendation
made by Defendant, the Oftices, or a recommendation made jointly by Defendant and the Office.
Defendant agrees, in an individual and any other capacity, to forfeit to the United
States, voluntarily and imm ediately, any right, title, and interest to any property, real or personal,
which constitm es or is derived from proceeds obtained directly or indirectly, as a result of the
violation to which he is pleading guilty, pursuant to l 8 U.S.C. j 982(a)(2)(A). In addition,
Defendant agrees to forfeiture of substitute property pursuant to Title 21, United States Code,
Section 8534.19. The property subject to forfeiture includes, but is not limited to:
a.
which sum represents the approximate value of the property subject to forfeiture.
a forfeiture money judgment in the sllm of $ 1 17,000 in U.S. currency,
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10. 
Defendant further agrees that forfeiture is independent of any assessm ent, tine, cost,
restitution, or penalty that m ay be imposed by the Court. Defendant knowingly and voluntarily
agrees to waive a1l constimtional, legal, and equitable defenses to the forfeiture, including
excessive tines under the Eighth Amendm ent to the United States Constitution. ln addition,
Defendant agrees to waive: any applicable time limits for administrative or judicial forfeiture
proceedings, the requirements of Fed. R. Crim. P. 32.2 and 43(a), and any appeal of the forfeiture.
Defendant also agrees to fully and truthfully disclose the existence, nattzre and
location of all assets in which Defendant has or had any direct or indirect financial interest or
control, and any assets involved in the offense of conviction. Defendant also agrees to take a11
steps requested by the United States for the recovery and forfeiture of al1 assets identitied by the
United States as subject to forfeimre. This includes, but is not limited to, the timely delive!y upon
request of all necessary and appropriate documentation to deliver good and marketable title,
consenting to a1l orders of forfeiture, and not contesting or impeding in any way with any crim inal,
civil or adm inistrative forfeittzre proceeding concem ing the forfeiture.
12. 
ln furtherance of the satisfaction of a fodkiture money judgment entered by the
Court in this case, Defendant agrees to the following:
a.
subm it a tinancial statem ent to the Office upon request, within 14
calendar days from the request;
maintain any asset valued in excess of $10,000, and not sell, hide,
waste, encumber, destroy, or otherwise devalue such asset without
b.
prior approval of the United States;
5
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C.
provide infonuation about any transfer of an asset valued in excess
of $10,000 since the commencement of the offense conduct in this
case to date;
cooperate fully in the investigation and the identification of assets,
including liquidating assets, m eeting with representatives of the
United States, and providing any documentation requested; and
d.
e.
notify, within 30 days, the Clerk of the Court for the Southern
District of Florida and the
residence, or m ailing
economic circum stances.
Oftice of: (i) any change of name,
address, and (ii) any material change in
Defendant f'urther understands that providing false or incomplete information about assets,
concealing assets, m aking m aterially false statements or representations, or m aking or using false
writings or docum ents pertaining to assets, taking any action that w ould im pede the forfeiture of
assets, or failing to cooperate fully in the investigation and identification of assets may be used as
a basis for: (i) separate prosecution, including, under 18 U.S.C. j 1001', or (ii) recommendation of
a denial of a reduction for acceptance of responsibility pursuant to the United States Sentencing
Guidelines j 3E1.l .
Defendant understands and acknowledges that the Court must order restitution for
the full amount of the victims' losses pursuant to 18 U.S.C. j 3663A. Defendant understands that
the amount of restitmion owed to the victimts) will be detenuined at or before sentencing unless
the Court orders otherwise. The Oftice and Defendant agree that the approxim ate am ount of
restitm ion Defendant owes to the U.S. Small Business Administration is $2,337,615.
6
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14. 
Defendant recognizes that pleading guilty m ay have consequences with respect to
Defendant's imm igration stat'us if Defendant is not a nattzral-boz.n citizen of the United States.
Under federal law, a broad range of crimes are rem ovable offenses, including the offense to which
Defendant is pleading guilty. In addition, under certain circum stances, denaturalization may also
be a consequence of pleading guilty to a clime. Rem oval, denatlzralization, and other im migration
consequences are the subject of a separate proceeding, however, and Defendant understands that
no one, including Defendant's attorney or the Coult can predict to a certainty the effect of
Defendant's conviction on Defendant's imm igration stattzs. Defendant nevertheless affirms that
Defendant wants to plead guilty regardless of any im migration consequences that Defendant's plea
may entail, even if the consequence is D efendant's denaturalization and autom atic rem oval from
the United States.
15. 
Defendant contirm s that Defendant is guilty of the offense to which Defendant is
pleading gtlilty; that Defendant's decision to plead guilty is the decision that Defendant has m ade;
and that nobody has forced, threatened, or coerced Defendant into pleading guilty. Defendant
affirm s that Defendant has reviewed this agreem ent and enters into it knowingly, voluntarily, and
intelligently, and with the benefit of assistance of Defendant's attorney.
l6. 
Defendant is aware that Title 18, United States Code, Section 3742 and Title 28,
United States Code, Section 1291 afford Defendant the light to appeal the sentence imposed in
this case. Acknowledging this, in exchange for the undertakings m ade by the United States in this
plea agreem ent, Defendant hereby waives all rights conferred by Sections 3742 and 1291 to appeal
any sentence im posed, including any restitution order, or to appeal the m anner in which the
sentence was imposed, unless the sentence exceeds the maximum permitted by statute or is the
Case 0:26-cr-60019-RKA   Document 23   Entered on FLSD Docket 04/27/2026   Page 7 of 9

result of an upward departure and/or an upward variance from the advisory guideline range that
the Court establishes at sentencing. Defendant further understands that nothing in this agreem ent
shall affect the govem m ent's right and/or duty to appeal as set forth in Title 18, United States
Code, Section 3742(b) and Title 28, United States Code, Section 1291. However, if the United
States appeals Defendant's sentence pursuant to Sections 3742418 and 1291, Defendant shall be
released from the above waiver of appellate rights. By signing this agreem ent, Defendant
acknowledges that Defendant has discussed the appeal waiver set forth in this agreement with
Defendant's attom ey. Defendant further agrees, together with the Office, to request that the Court
enter a specific finding that Defendant's waiver of his right to appeal the sentence imposed in this
case was knowing and voluntary.
l7. 
Should Defendant withdraw, or attempt to withdraw, from this plea agreement for
any reason, and does not plead guilty, Defendant understands and agrees that he thereby waives
any protection afforded by Rule 1 l of the Federal Rules of Criminal Procedure, Rule 410 of the
Rules of Evidence, and Section IB 1.8(a) of the United States Sentencing Guidelines. The
Defendant further understands that if for any reason he does not plead guilty, any statem ents he
m ade to the government, including any factual statem ent prepared for submission to the Court in
connection with Defendant's guilty plea, will become admissible as evidence and may be
introduced affinnatively by the United States against Defendant in any criminal proceeding which
m ay then be in effect or which m ay at any f'uture time be initiated by the United States.
18. 
This is the entire agreem ent and understanding between the Oftice and Defendant.
There are no other agreements, prom ises, representations, or understandings.
8
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Date: 
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UN ITED STATES ATTORN EY
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Date: 12/172025
Case 0:26-cr-60019-RKA   Document 23   Entered on FLSD Docket 04/27/2026   Page 9 of 9

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