Proposed Verdict Sheet — No. 1:21-cr-00470 (Dkt. 144, D. Md.)

Summary

This 31-page proposed verdict sheet, filed June 17, 2024 in Criminal No. MJM-21-470 in the District of Maryland, covers bank fraud and false statement charges against Nichelle Henson, including a false statement to a bank on an April 14, 2020 EIDL application for Your Friendly Tax Preparation Services LLC. For each charge it offers Guilty, Not Guilty and Acquitted. It then asks jurors whether they are sure about the decision and to explain any doubt briefly. The instructions tell jurors that the defendant, acting pro se, does not have a lawyer's legal training and that they may consider this when evaluating the evidence.

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Case 1:21-cr-00470-MJM Document144_ Filed 06/17/24 Page1of31

Proposed Verdict Sheet


Case 1:21-cr-00470-MJM Document144_ Filed 06/17/24 Page 2 of 31

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF MARYLAND

*
UNITED STATES OF AMERICA :
*
*

V. * Criminal No. MJM-21-470

*
NICHELLE HENSON x
*
*
*

q RRR RR RRR RR RRR ERR REAR R REY

Verdict Form

Charges:

Bank Fraud (18 U.S.C. § 1344)

False Statement to a Bank (18 U.S.C. § 1014)

Instructions:

The jury must reach a unanimous verdict on each charge. Please consider the following questions

for each charge and circle your verdict. After reaching a verdict on all charges, please return this

form to the court clerk.

Please consider each charge separately and reach a verdict based on the evidence presented at
trial. The government has the burden of proving the defendant guilty beyond a reasonable doubt

on each charge. This is the highest standard of proof in the criminal justice system.


Case 1:21-cr-00470-MJM Document144_ Filed 06/17/24 Page3of31

A reasonable doubt is a doubt that is based on reason and common sense. It is not a mere guess

or hunch.

The Defendant, acting as their own attorney (pro se), does not have the same legal training as a

professional lawyer. You may consider this when evaluating the evidence presented.

This means that after considering all the evidence, you must be firmly convinced of the
defendant's guilt. If you are not convinced, or if there is any reasonable doubt about the
defendant's guilt, you must find the defendant not guilty. If you find the Defendant not guilty on

any or all charges, you are not required to explain your verdict.

Charges 1-6: False Statement

CHARGE ONE: False statement to a bank

April 14, 2020 EIDL Application for Your Friendly Tax Preparation Services LLC

Do you find the United States has proven beyond a reasonable doubt that the Defendant,
NICHELLE HENSON, knowingly made a false statement to a bank for the purpose of

influencing the bank's action?

Yes * No

Understanding Your Verdict on Charge 1:

In order to find the Defendant guilty of False Statement to a Bank, the United States must have

proven all of the following elements beyond a reasonable doubt:

1. The Defendant made a false statement to a bank.
2. The statement was material, meaning it could have influenced the bank’s decision.

3. The Defendant made the statement knowingly and willfully.

2

Case 1:21-cr-00470-MJM Document144_ Filed 06/17/24 Page4of31

4. The statement related to a loan or other credit.

If you are unsure about any of these elements, you must find the Defendant NOT GUILTY.

Verdict

Charge 1: False Statements to a bank

Guilty * Not Guilty * Acquitted

Are you sure the Defendant knowingly made a false statement to a bank beyond a reasonable

doubt?

Yes

No

If you answered "Yes" to Charge 1, please answer the following question:

Are you sure about your decision?

Yes

No

If you answered ''No," please explain your doubt briefly.

CHARGE TWO: False Statements to a bank

June 19, 2020 EIDL Application for One Stop for Services LLC

Do you find the United States has proven beyond a reasonable doubt that the Defendant,
NICHELLE HENSON, knowingly made a false statement to a bank for the purpose of

influencing the bank's action?

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Yes * No
Understanding Your Verdict on Charge 2:

In order to find the Defendant guilty of False Statement to a Bank, the United States must have

proven all of the following elements beyond a reasonable doubt:

1. The Defendant made a false statement to a bank.
2. The statement was material, meaning it could have influenced the bank’s decision.
3. The Defendant made the statement knowingly and willfully.

4. The statement related to a loan or other credit.

If you are unsure about any of these elements, you must find the Defendant NOT GUILTY.

Verdict

Charge 2: False Statements to a bank

Guilty * Not Guilty * Acquitted

Are you sure the Defendant knowingly made a false statement to a bank beyond a reasonable

doubt?

Yes

No


Case 1:21-cr-00470-MJM Document144 _ Filed 06/17/24 Page6of31

If you answered "Yes" to Charge 2, please answer the following question:
Are you sure about your decision?

Yes

No

If you answered "No," please explain your doubt briefly.

CHARGE THREE: False statement to a bank

June 19, 2020 EIDL Application for Nichelle Henson Campaign LLC

Do you find the United States has proven beyond a reasonable doubt that the Defendant,
NICHELLE HENSON, knowingly made a false statement to a bank for the purpose of

influencing the bank's action?

Yes * No

Understanding Your Verdict on Charge 3:

In order to find the Defendant guilty of False Statement to a Bank, the United States must have

proven all of the following elements beyond a reasonable doubt:

1. The Defendant made a false statement to a bank.

N

The statement was material, meaning it could have influenced the bank’s decision.

we

. The Defendant made the statement knowingly and willfully.

4. The statement related to a loan or other credit.

If you are unsure about any of these elements, you must find the Defendant NOT GUILTY.

Case 1:21-cr-00470-MJM Document144_ Filed 06/17/24 Page /7of31

Verdict

Charge 3: False Statements to a bank

Guilty * Not Guilty * Acquitted

Are you sure the Defendant knowingly made a false statement to a bank beyond a reasonable

doubt?

Yes

No

If you answered "Yes" to Charge 3, please answer the following question:

Are you sure about your decision?

Yes

No

If you answered "No," please explain your doubt briefly.

CHARGE FOUR: False statement to a bank

June 19, 2020 EIDL Application for Peace of Mind Services Inc.

Do you find the United States has proven beyond a reasonable doubt that the Defendant,
NICHELLE HENSON, knowingly made a false statement to a bank for the purpose of

influencing the bank's action?

Yes * No

Case 1:21-cr-00470-MJM Document144_ Filed 06/17/24 Page 8of31

Understanding Your Verdict on Charge 4:

In order to find the Defendant guilty of False Statement to a Bank, the United States must have

proven all of the following elements beyond a reasonable doubt:

1. The Defendant made a false statement to a bank.
2. The statement was material, meaning it could have influenced the bank’s decision.
3. The Defendant made the statement knowingly and willfully.

4. The statement related to a loan or other credit.
If you are unsure about any of these elements, you must find the Defendant NOT GUILTY.
Verdict
Charge 4: False Statements to a bank
Guilty * Not Guilty * Acquitted

Are you sure the Defendant knowingly made a false statement to a bank beyond a reasonable

doubt?

Yes

No

If you answered "Yes" to Charge 4, please answer the following question:
Are you sure about your decision?

Yes

No


Case 1:21-cr-00470-MJM Document144_ Filed 06/17/24 Page9of31

If you answered "No," please explain your doubt briefly.
y

CHARGE FIVE: False statement to a bank

April 7, 2021 EIDL Application for Nichelle Henson Campaign LLC

Do you find the United States has proven beyond a reasonable doubt that the Defendant,
NICHELLE HENSON, knowingly made a false statement to a bank for the purpose of

influencing the bank's action?

Yes * No

Understanding Your Verdict on Charge 5:

In order to find the Defendant guilty of False Statement to a Bank, the United States must have

proven all of the following elements beyond a reasonable doubt:

1. The Defendant made a false statement to a bank.
2. The statement was material, meaning it could have influenced the bank’s decision.
3. The Defendant made the statement knowingly and willfully.

4. The statement related to a loan or other credit.

If you are unsure about any of these elements, you must find the Defendant NOT GUILTY.

Verdict

Charge 5: False Statements to a bank

Guilty * Not Guilty * Acquitted


Case 1:21-cr-00470-MJM Document144_ Filed 06/17/24 Page10of31

Are you sure the Defendant knowingly made a false statement to a bank beyond a reasonable

doubt?

Yes

No

If you answered "Yes" to Charge 5, please answer the following question:
Are you sure about your decision?

Yes

No

If you answered "No," please explain your doubt briefly.

CHARGE SIX: False statement to a bank

April 7, 2021 EIDL Application for Your Friendly Tax Preparation Services LLC

Do you find the United States has proven beyond a reasonable doubt that the Defendant,
NICHELLE HENSON, knowingly made a false statement to a bank for the purpose of

influencing the bank's action?

Yes * No

Understanding Your Verdict on Charge 6:

In order to find the Defendant guilty of False Statement to a Bank, the United States must have

proven all of the following elements beyond a reasonable doubt:

1. The Defendant made a false statement to a bank.


Case 1:21-cr-00470-MJM Document144 _ Filed 06/17/24 Page11of 31

2. The statement was material, meaning it could have influenced the bank’s decision.
3. The Defendant made the statement knowingly and willfully.

4. The statement related to a loan or other credit.
If you are unsure about any of these elements, you must find the Defendant NOT GUILTY.
Verdict
Charge 6: False Statements to a bank
Guilty * Not Guilty * Acquitted

Are you sure the Defendant knowingly made a false statement to a bank beyond a reasonable

doubt?

Yes

No

If you answered "Yes" to Charge 6, please answer the following question:
Are you sure about your decision?

Yes

No

If you answered "No," please explain your doubt briefly.

10

Case 1:21-cr-00470-MJM Document144 _ Filed 06/17/24 Page 12 of 31

Charges 7-12: Bank Fraud
CHARGE SEVEN: Bank Fraud
April 30, 2020 PPP Loan Application for Your Friendly Tax Preparation Services LLC

Do you find the United States has proven beyond a reasonable doubt that the Defendant,
Nichelle Henson, knowingly executed or attempted to execute a scheme to defraud a financial

institution?
Yes * No
Understanding Your Verdict on Charge 7: Bank Fraud

In order to find the Defendant guilty of Bank Fraud, the United States must have proven all of

the following elements beyond a reasonable doubt:

1. Ascheme to defraud a financial institution.

2. The Defendant knowingly participated in the scheme.

3. The Defendant’s participation in the scheme intended to or potentially could have
resulted in a financial loss to the institution.

4. Engaged in a scheme to defraud a financial institution.

5. Did so with the intent to deceive.

6. Materially affected the financial institution.

If you are unsure about any of these elements, you must find the Defendant NOT GUILTY.

11

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Verdict

Charge 7: Bank Fraud

Guilty * Not Guilty * Acquitted

Are you sure the Defendant knowingly participated in a scheme to defraud a bank beyond a

reasonable doubt?

Yes

No

If you answered "Yes" to Charge 7, please answer the following question:

Are you sure about your decision?

Yes

No

If you answered "No," please explain your doubt briefly.

CHARGE EIGHT: Bank Fraud

May 10, 2020 PPP Loan Application for Nichelle Henson Campaign LLC

Do you find the United States has proven beyond a reasonable doubt that the Defendant,
Nichelle Henson, knowingly executed or attempted to execute a scheme to defraud a financial

institution?

Yes * No

12


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Understanding Your Verdict on Charge 8: Bank Fraud

In order to find the Defendant guilty of Bank Fraud, the United States must have proven all of

the following elements beyond a reasonable doubt:

1. A scheme to defraud a financial institution.
2. The Defendant knowingly participated in the scheme.
3. The Defendant’s participation in the scheme intended to or potentially could have

resulted in a financial loss to the institution.

4, Engaged in a scheme to defraud a financial institution.
5. Did so with the intent to deceive.
6. Materially affected the financial institution.

If you are unsure about any of these elements, you must find the Defendant NOT GUILTY.

Verdict

Charge 8: Bank Fraud

Guilty * Not Guilty * Acquitted

Are you sure the Defendant knowingly participated in a scheme to defraud a bank beyond a

reasonable doubt?

Yes

No

13


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If you answered "Yes" to Charge 8, please answer the following question:
Are you sure about your decision?

Yes

No

If you answered "No," please explain your doubt briefly.

CHARGE NINE: Bank Fraud

May 14, 2020 PPP Loan Application for One Stop for Services LLC

Do you find the United States has proven beyond a reasonable doubt that the Defendant,
Nichelle Henson, knowingly executed or attempted to execute a scheme to defraud a financial

institution?

Yes * No

Understanding Your Verdict on Charge 9: Bank Fraud

In order to find the Defendant guilty of Bank Fraud, the United States must have proven all of

the following elements beyond a reasonable doubt:

1. A scheme to defraud a financial institution.

2. The Defendant knowingly participated in the scheme.

3. The Defendant’s participation in the scheme intended to or potentially could have

resulted in a financial loss to the institution.

4, Engaged in a scheme to defraud a financial institution.

14

Case 1:21-cr-00470-MJM Document144 _ Filed 06/17/24 Page 16 of 31

5. Did so with the intent to deceive.

6. Materially affected the financial institution.

If you are unsure about any of these elements, you must find the Defendant NOT GUILTY.
Verdict

Charge 9: Bank Fraud

Guilty * Not Guilty * Acquitted

Are you sure the Defendant knowingly participated in a scheme to defraud a bank beyond a

reasonable doubt?

Yes

No

If you answered "Yes" to Charge 9, please answer the following question:
Are you sure about your decision?

Yes

No

If you answered "No," please explain your doubt briefly.

15

Case 1:21-cr-00470-MJM Document144 _ Filed 06/17/24 Page17 of 31

CHARGE TEN: Bank Fraud

June 20, 2020 PPP Loan Application for Peace of Mind Services Inc.
Do you find the United States has proven beyond a reasonable doubt that the Defendant,
Nichelle Henson, knowingly executed or attempted to execute a scheme to defraud a financial

institution?

Yes * No

Understanding Your Verdict on Charge 10: Bank Fraud

In order to find the Defendant guilty of Bank Fraud, the United States must have proven all of

the following elements beyond a reasonable doubt:

1. A scheme to defraud a financial institution.

2. The Defendant knowingly participated in the scheme.

3. The Defendant’s participation in the scheme intended to or potentially could have

resulted in a financial loss to the institution.

4. Engaged in a scheme to defraud a financial institution.
5. Did so with the intent to deceive.
6. Materially affected the financial institution.

If you are unsure about any of these elements, you must find the Defendant NOT GUILTY.

16


Case 1:21-cr-00470-MJM Document144 _ Filed 06/17/24 Page 18 of 31

Verdict
Charge 10: Bank Fraud
Guilty * Not Guilty * Acquitted

Are you sure the Defendant knowingly participated in a scheme to defraud a bank beyond a

reasonable doubt?

Yes

No

If you answered "Yes" to Charge 10, please answer the following question:
Are you sure about your decision?

Yes

No

If you answered "No," please explain your doubt briefly.

CHARGE ELEVEN: Bank Fraud

June 23, 2020 PPP Loan Application for Women Entrepreneurs Can Succeed LLC

Do you find the United States has proven beyond a reasonable doubt that the Defendant,
Nichelle Henson, knowingly executed or attempted to execute a scheme to defraud a financial

institution?

Yes * No

17

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Understanding Your Verdict on Charge 11: Bank Fraud

In order to find the Defendant guilty of Bank Fraud, the United States must have proven all of

the following elements beyond a reasonable doubt:

1. A scheme to defraud a financial institution.

2. The Defendant knowingly participated in the scheme.

3. The Defendant’s participation in the scheme intended to or potentially could have

resulted in a financial loss to the institution.

4, Engaged in a scheme to defraud a financial institution.
5. Did so with the intent to deceive.
6. Materially affected the financial institution.

If you are unsure about any of these elements, you must find the Defendant NOT GUILTY.

Verdict

Charge 11: Bank Fraud

Guilty * Not Guilty * Acquitted

Are you sure the Defendant knowingly participated in a scheme to defraud a bank beyond a

reasonable doubt?

Yes

No

18


Case 1:21-cr-00470-MJM Document144 _ Filed 06/17/24 Page 20 of 31

If you answered "Yes" to Charge 11, please answer the following question:
Are you sure about your decision?

Yes

No

If you answered "No," please explain your doubt briefly.

CHARGE TWELVE: Bank Fraud
June 23, 2020 PPP Loan Application for Women Entrepreneurs Can Succeed LLC

Do you find the United States has proven beyond a reasonable doubt that the Defendant,
Nichelle Henson, knowingly executed or attempted to execute a scheme to defraud a financial

institution?
Yes * No
Understanding Your Verdict on Charge 12: Bank Fraud

In order to find the Defendant guilty of Bank Fraud, the United States must have proven all of

the following elements beyond a reasonable doubt:

1. A scheme to defraud a financial institution.
2. The Defendant krowingly participated in the scheme.
3. The Defendant’s participation in the scheme intended to or potentially could have

resulted in a financial loss to the institution.

4. Engaged in a scheme to defraud a financial institution.

19

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5. Did so with the intent to deceive.

6. Materially affected the financial institution.

If you are unsure about any of these elements, you must find the Defendant NOT GUILTY.
Verdict

Charge 12: Bank Fraud

Guilty * Not Guilty * Acquitted

Are you sure the Defendant knowingly participated in a scheme to defraud a bank beyond a

reasonable doubt?

Yes

No

If you answered "Yes" to Charge 12, please answer the following question:
Are you sure about your decision?

Yes

No

If you answered "No," please explain your doubt briefly.

20

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Charges 13-18: Bank Fraud (Second Draw PPP Loans)
CHARGE THIRTEEN: Bank Fraud
January 19, 2021 PPP Loan Application for Your Friendly Tax Preparation Services LLC

Do you find the United States has proven beyond a reasonable doubt that the Defendant,
Nichelle Henson, knowingly executed or attempted to execute a scheme to defraud a financial

institution?
Yes * No
Understanding Your Verdict on Charge 13: Bank Fraud

In order to find the Defendant guilty of Bank Fraud, the United States must have proven all of

the following elements beyond a reasonable doubt:
1. A scheme to defraud a financial institution.
2. The Defendant knowingly participated in the scheme.

3. The Defendant’s participation in the scheme intended to or potentially could have

resulted in a financial loss to the institution.

4, Engaged in a scheme to defraud a financial institution.
5. Did so with the intent to deceive.
6. Materially affected the financial institution.

If you are unsure about any of these elements, you must find the Defendant NOT GUILTY.

21

Case 1:21-cr-00470-MJM Document144 _ Filed 06/17/24 Page 23 of 31

Verdict

Charge 13: Bank Fraud

Guilty * Not Guilty * Acquitted

Are you sure the Defendant knowingly participated in a scheme to defraud a bank beyond a

reasonable doubt?

Yes

No

If you answered "Yes" to Charge 13, please answer the following question:

Are you sure about your decision?

Yes

No

If you answered "No," please explain your doubt briefly.

CHARGE FOURTEEN: Bank Fraud

January 19, 2021 PPP Loan Application for Nichelle Henson Campaign LLC

Do you find the United States has proven beyond a reasonable doubt that the Defendant,

Nichelle Henson, knowingly executed or attempted to execute a scheme to defraud a financial

institution?

Yes * No

22

Case 1:21-cr-00470-MJM Document 144 Filed 06/17/24 Page 24 of 31

Understanding Your Verdict on Charge 14: Bank Fraud

In order to find the Defendant guilty of Bank Fraud, the United States must have proven all of

the following elements beyond a reasonable doubt:
1. A scheme to defraud a financial institution.
2. The Defendant knowingly participated in the scheme.

3. The Defendant’s participation in the scheme intended to or potentially could have

resulted in a financial loss to the institution.

4, Engaged in a scheme to defraud a financial institution.
5. Did so with the intent to deceive.
6. Materially affected the financial institution.

If you are unsure about any of these elements, you must find the Defendant NOT GUILTY.

Verdict

Charge 14: Bank Fraud

Guilty * Not Guilty * Acquitted

Are you sure the Defendant knowingly participated in a scheme to defraud a bank beyond a

reasonable doubt?
Yes

No

23


Case 1:21-cr-00470-MJM Document144 _ Filed 06/17/24 Page 25 of 31

If you answered "Yes" to Charge 14, please answer the following question:
Are you sure about your decision?

Yes

No

If you answered "No," please explain your doubt briefly.

CHARGE FIFTHTEEN: Bank Fraud
January 19, 2021 PPP Loan Application for One Stop for Services LLC

Do you find the United States has proven beyond a reasonable doubt that the Defendant,
Nichelle Henson, knowingly executed or attempted to execute a scheme to defraud a financial

institution?
Yes * No
Understanding Your Verdict on Charge 15: Bank Fraud

In order to find the Defendant guilty of Bank Fraud, the United States must have proven all of

the following elements beyond a reasonable doubt:

1. A scheme to defraud a financial institution.
2. The Defendant knowingly participated in the scheme.
3. The Defendant’s participation in the scheme intended to or potentially could have

resulted in a financial loss to the institution.

4, Engaged in a scheme to defraud a financial institution.

24

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5. Did so with the intent to deceive.

6. Materially affected the financial institution.

If you are unsure about any of these elements, you must find the Defendant NOT GUILTY.
Verdict

Charge 15: Bank Fraud

Guilty * Not Guilty * Acquitted

Are you sure the Defendant knowingly participated in a scheme to defraud a bank beyond a

reasonable doubt?

Yes

No

If you answered "Yes" to Charge 15, please answer the following question:
Are you sure about your decision?

Yes

No

If you answered "No," please explain your doubt briefly.

25

Case 1:21-cr-00470-MJM Document144 _ Filed 06/17/24 Page 27 of 31

CHARGE SIXTEEN: Bank Fraud

January 19, 2021 PPP Loan Application for Peace of Mind Services Inc.

Do you find the United States has proven beyond a reasonable doubt that the Defendant,
Nichelle Henson, knowingly executed or attempted to execute a scheme to defraud a financial

institution?

Yes * No

Understanding Your Verdict on Charge 16: Bank Fraud

In order to find the Defendant guilty of Bank Fraud, the United States must have proven all of

the following elements beyond a reasonable doubt:

1. A scheme to defraud a financial institution.

2. The Defendant knowingly participated in the scheme.

3. The Defendant’s participation in the scheme intended to or potentially could have

resulted in a financial loss to the institution.

4, Engaged in a scheme to defraud a financial institution.
5. Did so with the intent to deceive.
6. Materially affected the financial institution.

If you are unsure about any of these elements, you must find the Defendant NOT GUILTY.

26


Case 1:21-cr-00470-MJM Document144 _ Filed 06/17/24 Page 28 of 31

Verdict
Charge 16: Bank Fraud
Guilty * Not Guilty * Acquitted

Are you sure the Defendant knowingly participated in a scheme to defraud a bank beyond a

reasonable doubt?

Yes

No

If you answered "Yes" to Charge 16, please answer the following question:
Are you sure about your decision?

Yes

No

If you answered "No," please explain your doubt briefly.

CHARGE SEVENTEEN: Bank Fraud

January 19, 2021 PPP Loan Application for Women Entrepreneurs Can Succeed LLC

Do you find the United States has proven beyond a reasonable doubt that the Defendant,
Nichelle Henson, knowingly executed or attempted to execute a scheme to defraud a financial

institution?

Yes * No

27

Case 1:21-cr-00470-MJM Document144_ Filed 06/17/24 Page 29 of 31

Understanding Your Verdict on Charge 17: Bank Fraud

In order to find the Defendant guilty of Bank Fraud, the United States must have proven all of

the following elements beyond a reasonable doubt:
1. A scheme to defraud a financial institution.
2. The Defendant knowingly participated in the scheme.

3. The Defendant’s participation in the scheme intended to or potentially could have

resulted in a financial loss to the institution.

4, Engaged in a scheme to defraud a financial institution.
5. Did so with the intent to deceive.
6. Materially affected the financial institution.

If you are unsure about any of these elements, you must find the Defendant NOT GUILTY.

Verdict

Charge 17: Bank Fraud

Guilty * Not Guilty * Acquitted

Are you sure the Defendant knowingly participated in a scheme to defraud a bank beyond a

reasonable doubt?

Yes


Case 1:21-cr-00470-MJM Document144 _ Filed 06/17/24 Page 30 of 31

If you answered "Yes" to Charge 17, please answer the following question:
Are you sure about your decision?

Yes

No

If you answered "No," please explain your doubt briefly.

CHARGE EIGHTEEN: Bank Fraud

January 19, 2021 PPP Loan Application for Crowns Construction LLC

Do you find the United States has proven beyond a reasonable doubt that the Defendant,
Nichelle Henson, knowingly executed or attempted to execute a scheme to defraud a financial

institution?

Yes * No

Understanding Your Verdict on Charge 18: Bank Fraud

In order to find the Defendant guilty of Bank Fraud, the United States must have proven all of

the following elements beyond a reasonable doubt:

1. A scheme to defraud a financial institution.

2. The Defendant knowingly participated in the scheme.

3. The Defendant’s participation in the scheme intended to or potentially could have

resulted in a financial loss to the institution.

4. Engaged in a scheme to defraud a financial institution.

29


Case 1:21-cr-00470-MJM Document144 _ Filed 06/17/24 Page 31 of 31

5. Did so with the intent to deceive.

6. Materially affected the financial institution.

If you are unsure about any of these elements, you must find the Defendant NOT GUILTY.
Verdict

Charge 18: Bank Fraud

Guilty * Not Guilty * Acquitted

Are you sure the Defendant knowingly participated in a scheme to defraud a bank beyond a

reasonable doubt?

Yes

No

If you answered "Yes" to Charge 18, please answer the following question:
Are you sure about your decision?

Yes

No

If you answered "No," please explain your doubt briefly.

30

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