Plea Agreement — No. 2:23-cr-00090 (Dkt. 142, W.D. Wash.)

Summary

Paradise Shaw Dreia Williams agreed to plead guilty to wire fraud (Count 9) and money laundering (Count 26) in CR-23-090-01 JHC in the Western District of Washington; the agreement was filed December 11, 2023. Williams admits that from about June 2020 until February 2022 Williams and co-defendants submitted over 125 applications, seeking more than $6.8 million and obtaining more than $3.3 million, from emergency rental assistance, PPP, EIDL and other programs. The stated uses of the money include luxury cars, lavish trips, cosmetic surgery, jewelry and designer goods.

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Case 2:23-cr-00090-JHC Document 142 Filed 12/11/23 Page 1 of 23

a. FILED «= 5§§s CENTERED The Honorable John H. Chun
w—————. LODGED WW. RECEIVED

DEC 11 2023

CLERK US. DISTRIC
TRICT COURT
ey enn DISTRICT OF WASHINGTON

DEPUTY

UNITED STATES DISTRICT COURT FOR THE
WESTERN DISTRICT OF WASHINGTON

AT SEATTLE
UNITED STATES OF AMERICA, NO. CR-23-090-01 JHC
Plaintiff, PLEA AGREEMENT

PARADISE SHAW DREIJA WILLIAMS,
Defendant.

The United States, through Acting United States Attorney Tessa M. Gorman and
Assistant United States Attorney Cindy Chang of the Western District of Washington,
and Defendant Paradise Shaw Dreia Williams and Defendant’s attorney Michael C.
Nance enter into the following Plea Agreement, pursuant to Federal Rule of Criminal
Procedure 11(c)(1)(B).
l. The Charge. Defendant, having been advised of the right to have this
matter tried before a jury, agrees to waive that right and enters a plea of guilty to each of
the following charges contained in the Indictment:
a. Wire Fraud, as charged in Count 9, in violation of Title 18, United
States Code, Section 1343; and
Plea Agreement - 1 UNITED STATES ATTORNEY
United States v. Williams, CR23-090-01 JHC 700 STEWART STREET, SUITE 5220

SEATTLE, WASHINGTON 98101
(206) 553-7970

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Case 2:23-cr-00090-JHC Document 142 Filed 12/11/23 Page 2 of 23

b. Money Laundering, as charged in Count 26, in violation of Title 18,
United States Code, Section 1957.

By entering these pleas of guilty, Defendant hereby waives all objections to the
form of the charging document. Defendant further understands that before entering any
guilty plea, Defendant will be placed under oath. Any statement given by Defendant
under oath may be used by the United States in a prosecution for perjury or false
statement.

2. Elements of the Offense. The elements of the offenses to which
Defendant is pleading guilty are as follows:

a. The elements of Wire Fraud, as charged in Count 9, are as follows:

First, the Defendant knowingly participated in, or devised, a scheme or
plan for obtaining money or property through false or fraudulent pretenses,
representations or promises;

Second, the promises, statements, or representations were material, that is,
they had a natural tendency to influence a person to part with money or property;

Third, the Defendant acted with the intent to defraud;

Fourth, the Defendant used, or caused to be used, the wires in interstate or
foreign commerce to carry out or attempt to carry out an essential part of the
scheme; and

Fifth, the violation occurred in relation to, or involved, benefit payments
authorized, transmitted, disbursed or paid in connection with a presidentially-
declared major disaster or emergency.

b. The elements of Money Laundering, as charged in Count 26, are as
follows:

First, the Defendant knowingly engaged or attempted to engage in a
monetary transaction;

Plea Agreement - 2 UNITED STATES ATTORNEY
United States v. Williams, CR23-090-01 JHC 700 STEWART STREET, SUITE 5220

SEATTLE, WASHINGTON 98101
(206) 553-7970

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Case 2:23-cr-00090-JHC Document 142 Filed 12/11/23 Page 3 of 23

Second, the Defendant knew that transaction involved criminally derived
property;

Third, the property had a value greater than $10,000;

Fourth, the property was, in fact, derived from a specified unlawful
activity; and

Fifth, the transaction occurred in the United States.

3. The Penalties. Defendant understands that the statutory penalties
applicable to the offense to which Defendant is pleading guilty are as follows:

a. For the offense of Wire Fraud, as charged in Count 9: A maximum
term of imprisonment of up to 30 years, a fine of up to $1,000,000, a period of
supervision following release from prison of up to five years, and a mandatory
special assessment of $100. Ifa probationary sentence is imposed, the probation
period can be for up to five years.

b. For the offense of Money Laundering, as charged in Count 26: A
maximum term of imprisonment of up to 20 years, a fine of up to $500,000, a
period of supervision following release from prison of up to three years, and a
mandatory special assessment of $100. Ifa probationary sentenced is imposed,
the probation period can be for up to five years.

4. Immigration Consequences. Defendant recognizes that pleading guilty
may have consequences with respect to Defendant’s immigration status if Defendant is
not a citizen of the United States. Under federal law, a broad range of crimes are grounds
for removal, and some offenses make removal from the United States presumptively
mandatory. Removal and other immigration consequences are the subject of a separate
proceeding, and Defendant understands that no one, including Defendant’s attorney and
the Court, can predict with certainty the effect of a guilty plea on immigration status.

Defendant nevertheless affirms that Defendant wants to plead guilty regardless of any

Plea Agreement - 3 UNITED STATES ATTORNEY
United States v. Williams, CR23-090-01 JHC 700 STEWART STREET, SUITE 5220
SEATTLE, WASHINGTON 98101
(206) 553-7970

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Case 2:23-cr-00090-JHC Document 142 Filed 12/11/23 Page 4 of 23

immigration consequences that Defendant’s guilty pleas may entail, even if the
consequence is Defendant’s mandatory removal from the United States.
5. Rights Waived by Pleading Guilty. Defendant understands that by

pleading guilty, Defendant knowingly and voluntarily waives the following rights:

a. The right to plead not guilty and to persist in a plea of not guilty;

b. The right to a speedy and public trial before a jury of Defendant's
peers;

c. The right to the effective assistance of counsel at trial, including, if
Defendant could not afford an attorney, the right to have the Court appoint one for
Defendant;

d. The right to be presumed innocent until guilt has been established

beyond a reasonable doubt at trial;

e. The right to confront and cross-examine witnesses against Defendant
at trial;

f. The right to compel or subpoena witnesses to appear on Defendant’s
behalf at trial;

g. The right to testify or to remain silent at trial, at which trial such

silence could not be used against Defendant; and
h. The right to appeal a finding of guilt or any pretrial rulings.

6. United States Sentencing Guidelines. Defendant understands and
acknowledges that the Court must consider the sentencing range calculated under the
United States Sentencing Guidelines and possible departures under the Sentencing
Guidelines together with the other factors set forth in Title 18, United States Code,
Section 3553(a), including: (1) the nature.and circumstances of the offense(s); (2) the
history and characteristics of Defendant; (3) the need for the sentence to reflect the
seriousness of the offense(s), to promote respect for the law, and to provide just

punishment for the offense(s); (4) the need for the sentence to afford adequate deterrence

Plea Agreement - 4 UNITED STATES ATTORNEY
United States v. Williams, CR23-090-01 JHC 700 STEWART STREET, SUITE 5220
SEATTLE, WASHINGTON 98101
(206) 553-7970

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Case 2:23-cr-00090-JHC Document 142 Filed 12/11/23 Page 5 of 23

to criminal conduct; (5) the need for the sentence to protect the public from further
crimes of Defendant; (6) the need to provide Defendant with educational and vocational
training, medical care, or other correctional treatment in the most effective manner; (7)
the kinds of sentences available; (8) the need to provide restitution to victims; and (9) the
need to avoid unwarranted sentence disparity among defendants involved in similar
conduct who have similar records. Accordingly, Defendant understands and
acknowledges that:

a. The Court will determine Defendant’s Sentencing Guidelines range
at the time of sentencing;

b. After consideration of the Sentencing Guidelines and the factors in
18 U.S.C. 3553(a), the Court may impose any sentence authorized by law, up to the
maximum term authorized by law;

c. The Court is not bound by any recommendation regarding the
sentence to be imposed, or by any calculation or estimation of the Sentencing Guidelines
range offered by the parties or the United States Probation Department, or by any
stipulations or agreements between the parties in this Plea Agreement; and

d. Defendant may not withdraw a guilty plea solely because of the
sentence imposed by the Court.

7. Ultimate Sentence. Defendant acknowledges that no one has promised or
guaranteed what sentence the Court will impose.

8. Statement of Facts. Defendant admits Defendant is guilty of the charged
offense. The parties agree on the following facts and further agree that all of these facts
constitute relevant conduct under the United States Sentencing Guidelines:

a. Overview. From about June 2020 until February 2022, Defendants
Paradise Shaw Dreia Williams, D’arius Akim Jackson, Jahri Asad Cunningham, Tia
Janee Robinson, Rayvon Darnell Peterson, David Jesus Martinez, and others submitted

over 125 applications and fraudulently sought more than $6.8 million, and obtained more

Plea Agreement - 5 UNITED STATES ATTORNEY
United States v. Williams, CR23-090-01 JHC 700 STEWART STREET, SUITE 5220
SEATTLE, WASHINGTON 981014
(206) 553-7970

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Case 2:23-cr-00090-JHC Document 142 Filed 12/11/23 Page 6 of 23

than $3.3 million, from various federally-funded COVID-19 pandemic relief programs.
They used the funds intended to assist individuals and businesses suffering from the
economic impacts of the pandemic for extravagant expenses such as luxury cars, lavish
trips, cosmetic surgery, jewelry, and designer goods.

b. Defendants’ scheme targeted the following COVID-19 pandemic
relief programs: U.S. Department of Treasury’s Emergency Rental Assistance program
administered through Washington State grant programs and King County Eviction
Prevention and Rental Assistance Program (EPRAP); the Paycheck Protection Program
(PPP) administered by the U.S. Small Business Administration (SBA); the Economic
Injury Disaster Loan (EIDL) Program administered by SBA; and Coronavirus Aid,
Relief, and Economic Security (CARES) Act unemployment benefits administered
through various state workforce agencies, including those in California, South Carolina,
and Nevada.

on Emergency Rental Assistance, EIDL, PPP funds, and CARES Act
unemployment benefits were authorized, transferred, disbursed, and paid in connection
with a nationwide emergency declared by Presidential Proclamation 9994 (effective as of
March 1, 2020) and a Presidential declaration of a major disaster for the State of
Washington concerning the COVID-19 pandemic that was issued on March 22, 2020.

d. Williams orchestrated the scheme and artifice to defraud. In total,
Williams personally participated in the submission of over 125 fraudulent applications
for Emergency Rental Assistance, EIDL, PPP, and CARES Act unemployment funds.
Williams enlisted and directed dozens of uncharged associates, in addition to her five co-
defendants, to execute the scheme. Williams received more than $2 million in fraudulent
proceeds, either directly into bank accounts she controlled or in kickback payments she
demanded from her associates.

e. Williams, Jackson, Cunningham, Robinson, and Peterson, used their

own identities, including numerous aliases and the identities of others, to submit multiple

Plea Agreement - 6 UNITED STATES ATTORNEY
United States v. Williams, CR23-090-01 JHC 700 STEWART STREET, SUITE 5220
SEATTLE, WASHINGTON 98101
(206) 553-7970

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Case 2:23-cr-00090-JHC Document 142 Filed 12/11/23 Page 7 of 23

fraudulent applications to various programs. Williams, Jackson, Robinson, and Peterson
received kickback payments for fraudulently obtained benefits. The Defendants
impersonated and directed others to impersonate landlords and tenants in
communications with EPRAP staff who processed the applications. Williams created and
submitted fake bank statements and other documents to support the fraudulent
applications she and her associates submitted. Williams, and others, also created, used,
and maintained multiple email accounts, sometimes using alias names, to perpetuate the
fraudulent scheme.

f. Upon receipt of the fraudulent proceeds, the Defendants quickly and
methodically laundered the funds through cash withdrawals, wire transfers, and
expensive purchases.

g. Emergency Rental Assistance. In response to millions of
Americans facing deep rental debt, fear of evictions, and the loss of basic housing
security as a result of the COVID-19 pandemic, the U.S. Department of Treasury’s
Emergency Rental Assistance program provided funding directly to state and local
governments to assist households that were unable to pay rent or utilities. From March
2021 through 2022, Treasury’s Emergency Rental Assistance program allocated over
$900 million to Washington State and local governments, including King County. The
Washington Department of Commerce received and administered the state’s federal
funds by providing grants to county governments and non-profit organizations to support
the homeless crisis response systems in the state. In King County, the Department of
Community and Human Services distributed over $300 million in direct federal funds and
state grants to approximately 30,000 King County households through EPRAP. Non-
Profit Organization 1, which is based in Seattle, also received over $5 million in
federally-funded rental assistance grants from the Washington Department of Commerce

and distributed the funds to approximately 700 households.

Plea Agreement - 7 UNITED STATES ATTORNEY
United States v. Williams, CR23-090-01 JHC 700 STEWART STREET, SUITE 5220
SEATTLE, WASHINGTON 98101

(206) 553-7970

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h. To qualify for rental assistance, the household must have been low-
income, experiencing financial hardship due to the COVID-19 pandemic, and been at risk
of experiencing homelessness or currently experiencing housing instability. Tenants and
landlords could receive up to 12 months of rental assistance (nine months back or current
rent and three months advance). The administering agencies acknowledged that there
was insufficient funding to. help every household who qualified, thus, the screening
criteria was intended to target those most likely to become homeless but for the
assistance. .

i. At all times relevant to this case, in King County, a landlord could
initiate an application for EPRAP assistance by submitting a delinquent tenant’s
information, and the tenant and landlord could submit self-attestation forms to document
eligibility. Landlords were also required to submit W-9 forms and, upon request,
evidence of a lease or ledger. After EPRAP calculated the final assistance amount,
landlords received an EPRAP agreement by email that they were required to sign and
return via DocuSign using interstate wire transmissions. The agreement certified that the
signee was authorized to accept the emergency rental assistance payment in satisfaction
of rent owed by a tenant.

j. King County initiated payment of the EPRAP funds by using an
interstate wire to upload payment information to a bank server located outside
Washington State. EPRAP funds were disbursed to landlords via checks or ACH
payments using interstate wire transmissions.

k. Between on or about August 27, 2021, and February 11, 2022, the
Defendants, using their own and others’ identities and aliases, posed as landlords and
submitted at least 79 fraudulent applications for Emergency Rental Assistance funds,
seeking over $2.9 million and obtaining over $2.79 million. At all times relevant to this
case, none of the Defendants owned property in King County, and therefore, were not

landlords for any property in King County.

Plea Agreement - 8 UNITED STATES ATTORNEY
United States v. Williams, CR23-090-01 JHC 700 STEWART STREET, SUITE 5220
SEATTLE, WASHINGTON 98101
(206) 553-7970

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L. Williams personally submitted or participated in the submission of at
least 78 fraudulent applications for Emergency Rental Assistance funds to King County
and one fraudulent application to Non-Profit Organization 1. Williams created fictitious
EPRAP landlord accounts using aliases and the identities of her co-defendants and others.
Williams used real King County addresses and fake tenant names. Williams generated
fake documents that were submitted in support of the applications, including ledgers and
landlord attestations. In communications with EPRAP staff about the applications,
Williams and others at her direction pretended to be tenants and landlords associated with
the fraudulent applications Williams submitted.

m. Williams submitted at least 21 fraudulent applications using her
aliases “Shirley William” and “Shaw Williams” as the fictitious landlord’s name. These
applications sought and caused King County to pay at least $743,238 directly to bank
accounts Williams controlled. Williams submitted the remaining 58 fraudulent
applications, which obtained over $2 million in Emergency Rental Assistance payments,
using the names and aliases of Williams’ co-defendants and others. For each of these
applications, Williams demanded and received a substantial kickback payment from the
criminal proceeds.

n. As one example of this conduct, as charged in Count 9, on or about
November 11, 2021, until on or about November 17, 2021, Williams submitted two
fraudulent EPRAP applications associated with two fake tenants using the landlord alias
of “Shaw Williams.” In communications with EPRAP staff, Williams and others
impersonated the landlord and tenants for these applications. Williams created and
uploaded fake documents to create the “Shaw Williams” landlord account and support
these fraudulent applications. The landlord account for Shaw Williams directed King
County to pay the rental assistance into Williams’ Bank of America account. On or about
November 19, 2021, in connection with these two fraudulent EPRAP applications, King

Plea Agreement - 9 UNITED STATES ATTORNEY
United States v. Williams, CR23-090-01 JHC 700 STEWART STREET, SUITE 5220

SEATTLE, WASHINGTON 98104
(206) 553-7970

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Case 2:23-cr-00090-JHC Document 142 Filed 12/11/23 Page 10 of 23

County used interstate wires originating in King County, Washington to pay $83,280 in
Emergency Rental Assistance into Williams’ Bank of America account.

Oo. Within a week of the deposit from King County, Williams made
three separate cash withdrawals for $10,000 each. Additionally, on or about November
22, 2021, using criminal proceeds from the Emergency Rental Assistance scheme she
orchestrated, Williams wired approximately $31,343.12 to Auto Dealer I, in Seattle, to
purchase a 2017 Lexus ES Sedan (Vehicle Identification Number
58ABK1GG8HU072925). Williams knew the funds used to purchase the vehicle were
derived from the charged fraud scheme.

p. Similarly, as charged in Count 26, on or about February 18, 2022,
using the criminal proceeds from the Emergency Rental Assistance scheme she
orchestrated, Williams made a cash payment of $60,000 to Auto Dealer 1, in Seattle,
towards the purchase of a 2018 Range Rover sport utility vehicle (Vehicle Identification
Number SALYB2RV2JA727314). Williams used only $100 bills or higher and knew
that the cash was derived from the charged fraud scheme.

q. Paycheck Protection Program. PPP was a COVID-19 pandemic
relief program administered by SBA that provided forgivable loans to small businesses
for job retention and certain other expenses. The PPP permitted participating third-party
lenders to approve and disburse SBA-backed PPP loans to cover payroll, fixed debts,
utilities, rent/mortgage, accounts payable and other bills incurred by qualifying
businesses during and resulting from the COVID-19 pandemic. PPP loans were fully
guaranteed by the SBA. In the event of default, SBA will fully satisfy the lender for any
balance remaining on the loan. Further, SBA will forgive any loan up to 100 percent if
the borrower uses the funds for specified purposes.

r. To obtain a PPP loan, a qualifying business, which included certain
sole proprictorships, had to submit a PPP loan application, which was signed by an

authorized representative of the business. The PPP loan application required the business

Plea Agreement - 10 UNITED STATES ATTORNEY
United States v. Williams, CR23-090-01 JHC , 700 STEWART STREET, SUITE 5220
SEATTLE, WASHINGTON 98101
(206) 553-7970

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Case 2:23-cr-00090-JHC Document 142 Filed 12/11/23 Page 11 of 23

(through its authorized representative) to acknowledge the program rules and make
certain affirmative certifications to be eligible to obtain the PPP loan, including that the
business was in operation on February 15, 2020 and either had employees for whom it
paid salaries and payroll taxes or paid independent contractors. A business applying for a
PPP loan was required to provide documentation showing its payroll expenses, such as
filed federal income tax documents.

S. Individuals who operated a business under a “sole proprietorship”
business structure were also eligible for a PPP loan. To qualify for such a PPP loan,
individuals had to report and document their income and expenses from the sole
proprietorship, as typically reported to the Internal Revenue Service on a “Form 1040,
Schedule C,” for a given tax year. As with other PPP loans, this information and
supporting documentation was used to calculate the amount of money the individual was
entitled to receive under the PPP. The maximum loan amount for a sole proprietorship
with no employees was approximately $20,833.

t. At all times relevant to the charged offenses, PPP loan documents
were electronically submitted or caused to be submitted by the borrower to a third-party
lender service provider, which did not have any servers in Washington State. The
borrower signed the loan documents using DocuSign, which has servers within and
outside Washington State, and data for a single customer could reside in multiple
locations. The third-party lender service provider accessed the signed loan documents
and caused those documents to be sent to a third-party lender that did not have any
servers located within Washington State. Therefore, every PPP loan document relevant
to the charged offenses and initiated online from Washington State, resulted in an
interstate wire communication that originated in Washington State and traveled to
another state.

u. Once approved, the business received the PPP loan proceeds via an

electronic funds transfer from the third-party lender to a financial account under the

Plea Agreement - 11 UNITED STATES ATTORNEY
United States v. Williams, CR23-090-01 JHC 700 STEWART STREET, SUITE 5220
SEATTLE, WASHINGTON 98101
(206) 553-7970

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Case 2:23-cr-00090-JHC Document 142 Filed 12/11/23 Page 12 of 23

control of the business. The proceeds of a PPP loan could be used for certain specified
items, such as payroll costs, costs related to the continuation of group health care
benefits, or mortgage interest payments. The proceeds of a PPP loan were not permitted
to be used by the borrowers to purchase consumer goods, automobiles, personal
residences, clothing, jewelry, to pay the borrower’s personal federal income taxes, or to
fund the borrower’s ordinary day-to-day living expenses unrelated to the specified
authorized expenses.

Vv. Between on or about April 10, 2021, and May 23, 2021, Williams,
co-defendant Jackson, and others submitted at least 13 fraudulent PPP applications to
lenders who then transmitted the loan files using interstate transmissions. In total, the
applications sought approximately $253,000 and obtained approximately $211,730. In
exchange for facilitating and submitting the fraudulent applications, the individuals paid
Williams a kickback of approximately 50% upon receipt of the funds.

w. As one example of this conduct, on or about May 27, 2021, an
interstate wire originating in Washington was used to transmit a fraudulent PPP
application that Williams prepared in J.K.’s identity with J.K.’s authorization. The
application claimed that J.K. was a sole proprietor of a food delivery business that began
on January 1, 2020, with a gross income of $100,000. AII of these representations were
false, and Williams created and submitted a fake bank statement in support of the
application. The application directed loan proceeds to be paid into a bank account in
J.K.’s name. On or about June 7, 2021, the application was funded for $20,832, and the
proceeds were deposited into J.K.’s bank account. J.K. used multiple account transfers to
pay Williams approximately $10,000 in criminal proceeds.

Xx. Economic Injury Disaster Loan Program. SBA administers the
EIDL Program, which provides low-interest financing to small businesses and non-profit
organizations in regions affected by declared disasters. In March 2020, the CARES Act

authorized the SBA to provide EIDLs of up to $2 million to eligible small businesses

Plea Agreement - 12 UNITED STATES ATTORNEY
United States v. Williams, CR23-090-01 JHC 700 STEWART STREET, SUITE 5220
SEATTLE, WASHINGTON 98101
(206) 553-7970

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experiencing substantial financial disruption due to the COVID-19 pandemic. The
CARES Act and subsequent legislation also authorized the SBA to issue advances of up
to $10,000 to small businesses within three days of applying for an EIDL. EIDL
Advances did not have to be repaid. EIDL funds can be used for payroll expenses, sick
leave, production costs, and business obligations, such as debts, rent, and mortgage
payments.

y. . A qualifying business, which could include sole proprietorships, that
applied for an EIDL had to submit an application to the SBA and provide information
about its operations, such as the number of employees, gross revenues for the 12-month
period preceding the disaster, and cost of goods sold in the 12-month period preceding
the disaster. The applicant had to certify that all of the information in the application was
true and correct to the best of the applicant’s knowledge.

Z. Applicants submitted EIDL applications online directly to the SBA
for processing. SBA directly disbursed EIDL funds to an account identified by the
applicant. In all instances relevant to this Indictment, when an applicant submitted an
COVID-19 EIDL application online, SBA received it at a server outside Washington
State. Therefore, every COVID-19 EIDL application relevant to this Indictment and
submitted online from Washington State, resulted in an interstate wire communication
that originated in Washington State and traveled to another state.

aa. Beginning no later than June 25, 2020, until at least on or about
August 17, 2021, Williams submitted at least 35 fraudulent EIDL applications to SBA
using the identities of herself, her co-defendants, and others, seeking a total of
approximately $3.7 million and obtaining approximately $300,000. In exchange for
facilitating and submitting the fraudulent applications, the individuals who received
EIDL proceeds paid Williams a kickback upon receipt of the funds.

bb. Williams submitted at least three fraudulent EIDL applications using

her own identity and'‘maintained at least four email addresses that she repeatedly used to

Plea Agreement - 13 UNITED STATES ATTORNEY
United States v. Williams, CR23-090-01 JHC 700 STEWART STREET, SUITE 5220
SEATTLE, WASHINGTON 98101
(206) 553-7970

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submit the fraudulent applications. Williams also submitted multiple applications with
identical or strikingly similar business information. All of the applicants claimed to be
sole proprietorships, and most of the business or trade names followed the naming
convention of using the accomplice’s first name followed by “LLC.” For instance, the
trade name for co-defendant Jahri Cunningham was “JahriLLC.” Most of the fictitious
entities claimed to provide hair and nail services.

cc. As one example of this conduct, on or about July 13, 2020, Williams
submitted a fraudulent EIDL application using L.B.’s identity with L.B.’s authorization.
The application claimed that L.B. was a sole proprietor of a hair and nail salon, “Salon
LLC.” The application claimed gross revenues of $1,347,232 for the 12 months prior to
January 31, 2020, identified L.B. as the “Owner,” and claimed to have 18 employees as
of January 31, 2020. The business was purportedly established on April 3, 2017. All of
these representations were false. The application directed loan proceeds to be paid to
L.B.’s Bank of America account. On or about July 17, 2020, SBA funded the loan for
$150,000. Within a week of the disbursement into L.B.’s bank account on or about July
21, 2020, L.B. withdrew over $115,000 in a series of teller and ATM transactions. L.B.
also transferred over $11,000 to Williams using Cash App and made nearly $10,000 in
purchases at Yves Saint Lauren, Christian Dior, and Versace.

dd. CARES Act Unemployment Benefits. The CARES Act also
provided federal funding to expand unemployment benefits eligibility and increased
benefits, including the Pandemic Unemployment Assistance Program (PUA), Federal
Pandemic Unemployment Compensation (FPUC), and the Lost Wages Assistance
Program (LWAP). These benefits were administered through a joint state and federal
program that provided monetary benefits to eligible beneficiaries. Unemployment
benefits were intended to provide temporary financial assistance to lawful workers who

were unemployed through no fault of their own.

Plea Agreement - {4 UNITED STATES ATTORNEY
United States vy. Williams, CR23-090-01 JHC 700 STEWART STREET, SUITE 5220
SEATTLE, WASHINGTON 98101
(206) 553-7970

So Oo SI DB TH SP WY HK

— — —_ — — — — —_— —_
Oo Oo NIN WB Ur BP W NY | OS

20

Case 2:23-cr-00090-JHC Document 142 Filed 12/11/23 Page 15 of 23

ee. CARES Act unemployment benefits were funded by the United
States government through the Department of Labor and administered at the state level
by state agencies known as state workforce agencies. Generally, applicants could submit
applications for benefits online to state workforce agencies. Applicants had to answer
specific questions to establish eligibility to receive benefits, including their name, social
security number, and mailing address, among other things. Applicants also had to self-
certify that they met a COVID-19-related reason for being unemployed, partially
employed, or unable to work.

ff. Beginning on or about June 19, 2020, until on or about September 28,
2020, Williams submitted applications for CARES Act unemployment benefits in her
own identity to the state workforce agencies in Nevada and South Carolina despite the
fact that she had neither lived nor worked in those states in 2019 and 2020, as she
represented on the applications. These claims were denied without being paid. From
July 29, 2021, and continuing until at least August 11, 2021, Williams also attempted to
submit fraudulent unemployment applications in the identities of other individuals to the
state workforce agency for California.

The parties agree that the Court may consider additional facts contained in the
Presentence Report (subject to standard objections by the parties) and/or that may be
presented by the United States or Defendant at the time of sentencing, and that the factual
statement contained herein is not intended to limit the facts that the parties may present to
the Court at the time of sentencing.

9. Sentencing Factors. The parties agree that the following Sentencing
Guidelines provisions apply to this case:

The following provisions apply to defendant’s conviction of Counts 9 and 26:

a. All counts involve substantially the same harm and are grouped

together in a single group, pursuant to USSG § 3D.1.2(b), because the counts involve the

Plea Agreement - 15 UNITED STATES ATTORNEY
United States v. Williams, CR23-090-01 JHC 700 STEWART STREET, SUITE 5220
SEATTLE, WASHINGTON 98101
(206) 553-7970

So fe NDB WH FP WD YP

N NW NY NY WN i) i) iw) — _ —  — _ — = — —_
~ a oa) & we N — oS ‘oO io a} ~ on ws > oe) bo — >

Case 2:23-cr-00090-JHC Document 142 Filed 12/11/23 Page 16 of 23

same victim and two or more acts or transactions connected by a common criminal
objective or constituting part of a common scheme or plan;

b. A base offense level of 7, pursuant to USSG § 2B1.1(a)(1);

C. An increase of 18 points because the intended loss from the offense
exceeded $3,500,000 but was less than $9,500,000, pursuant to USSG § 2B1.1(b)(1)V);

d. An increase of two points because the offense involved sophisticated
means, pursuant to USSG § 2B1.1(b)(10);

e. An increase of two points because the offense involved benefits
authorized under a presidentially-declared major disaster or emergency, pursuant to
USSG § 2B1.1(b)(12);

£ An increase of one point because the defendant was convicted of
money laundering under 18 U.S.C. § 1957, pursuant to USSG § 281.1(b)(2)(A); and

g. An increase of four points because the defendant was an organizer or
leader of a criminal activity that involved five or more participants and was otherwise
extensive, pursuant to USSG § 3B1.1(a).

The parties agree they are free to present arguments regarding the applicability of
all other provisions of the United States Sentencing Guidelines. Defendant understands,
however, that at the time of sentencing, the Court is free to reject these stipulated
adjustments, and is further free to apply additional downward or upward adjustments in
determining Defendant’s Sentencing Guidelines range.

10. Acceptance of Responsibility. At sentencing, i/the Court concludes
Defendant qualifies for a downward adjustment for acceptance of responsibility pursuant
to USSG § 3E1.1(a) and Defendant’s offense level is 16 or greater, the United States will
make the motion necessary to permit the Court to decrease the total offense level by three
(3) levels pursuant to USSG §§ 3E1.1(a) and (b), because Defendant has assisted the

United States by timely notifying the United States of Defendant’s intention to plead

Plea Agreement - 16 UNITED STATES ATTORNEY
United States v. Williams, CR23-090-01 JHC 700 STEWART STREET, SUITE 5220
SEATTLE, WASHINGTON 98101
(206) 553-7970

—

DS th & WY LO

CoC oO nN

10
11
12
13
14

16
17
18
19
20
21
22
23

25
26
27

Case 2:23-cr-00090-JHC Document 142 Filed 12/11/23 Page 17 of 23

guilty, thereby permitting the United States to avoid preparing for trial and permitting the
Court to allocate its resources efficiently.

11. Recommendation Regarding Imprisonment. Pursuant to Federal Rule of
Criminal Procedure | 1(c)(1)(B), the government agrees to recommend that the
appropriate term of imprisonment to be imposed by the Court at the time of sentencing is
aterm of no more than 110 months. Defendant is free to recommend any sentence.
Defendant understands that this recommendation is not binding on the Court, and the
Court may reject the recommendation of the parties and may impose any term of
imprisonment up to the statutory maximum penalty authorized by law. Defendant
further understands that Defendant cannot withdraw a guilty plea simply because of the
sentence imposed by the Court. Except as otherwise provided in this Plea Agreement,
the parties are free to present arguments regarding any other aspect of sentencing.

12. Restitution. Defendant shall make restitution to the U.S. Department of
the Treasury in the amount of $2,791,241, with credit for any amounts already paid. The
Defendant shall also make restitution to the U.S. Small Business Administration in the
amount of $512,730, with credit for any amounts already paid.

a. The full amount of restitution shall be due and payable immediately
on entry of judgment and shall be paid as quickly as possible. Ifthe Court finds that the
defendant is unable to make immediate restitution in full and sets a payment schedule as
contemplated in 18 U.S.C. § 3664(f), Defendant agrees that the Court’s schedule
represents a minimum payment obligation and does not preclude the U.S. Attorney’s
Office from pursuing any other means by which to satisfy the defendant’s full and
immediately-enforceable financial obligation, including, but not limited to, by pursuing
assets that come to light only after the district court finds that the defendant is unable to
make immediate restitution.

b. Defendant agrees to disclose all assets in which Defendant has any

interest or over which Defendant exercises control, directly or indirectly, including those

Picea Agreement - 17 UNITED STATES ATTORNEY
United States v. Williams, CR23-090-01 JHC 700 STEWART STREET, SUITE 5220
SEATTLE, WASHINGTON 98101
(206) 553-7970

So Se SI DB A Re WD] BD

BO Rm
- oF Oo Ce NI DB WH BP WW NP | SC

22

Case 2:23-cr-00090-JHC Document 142 Filed 12/11/23 Page 18 of 23

held by a spouse, nominee, or third party. Defendant agrees to cooperate fully with the
United States’ investigation identifying all property in which Defendant has an interest
and with the United States’ lawful efforts to enforce prompt payment of the financial
obligations to be imposed in connection with this prosecution. Defendant’s cooperation
obligations are: (1) before sentencing, and no more than 30 days after executing this Plea
Agreement, truthfully and completely executing a Financial Disclosure Statement
provided by the United States Attorney’s Office and signed under penalty of perjury
regarding Defendant’s and Defendant’s spouse’s financial circumstances and producing
supporting documentation, including tax returns, as requested; (2) providing updates
with any material changes in circumstances, as described in 18 U.S.C. § 3664(k), within
seven days of the event giving rise to the changed circumstances; (3) authorizing the
United States Attorney’s Office to obtain Defendant’s credit report before sentencing; (4)
providing waivers, consents or releases requested by the U.S. Attorney’s Office to access
records to verify the financial information; (5) authorizing the U.S. Attorney’s Office to
inspect and copy all financial documents and information held by the U.S. Probation
Office; (6) submitting to an interview regarding Defendant’s Financial Statement and
supporting documents before sentencing (if requested by the United States Attorney’s
Office), and fully and truthfully answering questions during such interview; and (7)
notifying the United States Attorney’s Office before transferring any interest in property
owned directly or indirectly by Defendant, including any interest held or owned in any
other name, including all forms of business entities and trusts.

C. The parties acknowledge that voluntary payment of restitution prior
to the adjudication of guilt is a factor the Court considers in determining whether
Defendant qualifies for acceptance of responsibility pursuant to USSG § 3E1.1(a). In
addition, in any event, the government will consider Defendant’s cooperation regarding

restitution in making its sentencing recommendation.

Plea Agreement - 18 UNITED STATES ATTORNEY
United States vy. Williams, CR23-090-01 JHC 700 STEWART STREET, SUITE 5220
SEATTLE, WASHINGTON 98101
(206) 553-7970

Oo CO JN DBD A SP WwW Ne

ry
oH NY Bo Wn FP W NYO | SO

19
20
21
22
23
24
25
26
27

Case 2:23-cr-00090-JHC Document 142 Filed 12/11/23 Page 19 of 23

13. Forfeiture of Assets. Defendant understands that the forfeiture of property
is part of the sentence that must be imposed in this case.

Defendant agrees to forfeit to the United States immediately Defendant’s right,
title, and interest in any and all property that constitutes or is derived from proceeds
Defendant obtained from the wire-fraud scheme set forth above and charged in Count 9
of the Indictment. All such property is forfeitable pursuant to Title 18, United States
Code, Section, 981(a)(1)(C), by way of, Title 28, United States Code, Section 2461(c),
and includes but is not limited to:

a. a judgment for a sum of money, also known as a forfeiture money
judgment, in the amount of $2,023,104 representing the proceeds
Defendant personally obtained from her commission of the wire-

fraud scheme described above;

b. one Lexus ES Sedan, seized on or about June 5, 2023; and
C. one Range Rover Sport Utility Vehicle, seized on or about June 5,
2023.

Defendant further agrees to forfeit to the United States immediately Defendant’s
right, title, and interest in any and all property involved in the offense charged in Count
26 of the Indictment. Al] such.property is forfeitable pursuant to Title 18, United States
Code, Section 982(a)(1) and includes but is not limited to:

a. one Range Rover Sport Utility Vehicle, seized on or about June 5,
2023.

Defendant understands and acknowledges the forfeited sum of money set forth |
above is separate and distinct from any restitution that is ordered in this case. The United
States agrees, however, that it will request that the Attorney General apply any amounts it
collects toward satisfaction of this forfeited sum to the restitution that is ordered. The
United States also agrees that any amount Defendant pays toward restitution will be

credited against this forfeited sum.

Plea Agreement - 19 UNITED STATES ATTORNEY
United States v. Williams, CR23-090-01 JHC 700 STEWART STREET, SUITE 5220
SEATTLE, WASHINGTON 98101
(206) 553-7970

—

NO wo NO DN Kw BR NO DR es
I Ro Mn FP W NY | CO CO CC NH BDA FSP WO NY KF SOS

Ce UN DOW kB WwW DN

Case 2:23-cr-00090-JHC Document 142 Filed 12/11/23 Page 20 of 23

Defendant agrees to fully assist the United States in the forfeiture of the above-
described property and to take whatever steps are necessary to pass clear title to the
United States, including but not limited to: surrendering title and executing any
documents necessary to effect forfeiture; assisting in bringing any assets located outside
the United States within the jurisdiction of the United States; and taking whatever steps
are necessary to ensure that assets subject to forfeiture are not sold, disbursed, wasted,
hidden, or otherwise made unavailable for forfeiture. Defendant agrees not to file a claim
to any of the above-described property in any federal forfeiture proceeding,
administrative or judicial, which may be or has been initiated. Defendant further agrees
not to assist any party who may file a claim to this property in any federal forfeiture
proceeding.

The United States reserves its right to proceed against any remaining property not
identified in this Plea Agreement, including any property in which Defendant has any
interest or control, if that property constitutes or is traceable to proceeds of her
commission of the wire-fraud scheme described above and/or was involved in the offense
charged in Count 26.

14. Abandonment of Contraband. Defendant also agrees that, if any federal
law enforcement agency seized any illegal contraband that was in Defendant’s direct or
indirect control, Defendant consents to the federal administrative disposition, official use,
and/or destruction of that contraband.

15. Non-Prosecution of Additional Offenses. As part of this Plea Agreement,
the United States Attorney’s Office for the Western District of Washington agrees not to
prosecute Defendant for any additional offenses known to it as of the time of this Plea
Agreement based upon evidence in its possession at this time, and that arise out of the
conduct giving rise to this investigation, and moves to dismiss the remaining counts in
the Indictment at the time of sentencing. In this regard, Defendant recognizes the United

States has agreed not to prosecute all of the criminal charges the evidence establishes

Plea Agreement - 20 UNITED STATES ATTORNEY
United States v. Williams, CR23-090-01 JHC 700 STEWART STREET, SUITE 5220
SEAT TLE, WASHINGTON 98101
(206) 553-7970

Oo FF AYN DD FA Fe WY HO =

Le > NO SO Oe
FP Ww NY | 9D Oo Ce IN DH mH FP WD NY KH CSC

Wo
ws

26
27

Case 2:23-cr-00090-JHC Document 142 Filed 12/11/23 Page 21 of 23

were committed by Defendant solely because of the promises made by Defendant in this
Plea Agreement. Defendant agrees, however, that for purposes of preparing the
Presentence Report, the United States Attorney’s Office will provide the United States
Probation Office with evidence of all conduct committed by Defendant.

Defendant agrees that any charges to be dismissed before or at the time of
sentencing were substantially justified in light of the evidence available to the United
States, were not vexatious, frivolous or taken in bad faith, and do not provide Defendant
with a basis for any future claims under the “Hyde Amendment,” Pub. L. No. 105-119
(1997).

16. Breach, Waiver, and Post-Plea Conduct. Defendant agrees that, if
Defendant breaches this Plea Agreement: (a) the United States may withdraw from this
Plea Agreement and Defendant may be prosecuted for all offenses for which the United
States has evidence; (b) Defendant will not oppose any steps taken by the United States
to nullify this Plea Agreement, including the filing of a motion to withdraw from the Plea
Agreement; and (c) Defendant waives any objection to the re-institution of any charges
that previously were dismissed or any additional charges that had not been prosecuted.

Defendant further understands that if, after the date of this Plea Agreement,
Defendant should engage in illegal conduct, or conduct that violates any conditions of
release or the conditions of confinement (examples of which include, but are not limited
to, obstruction of justice, failure to appear for a court proceeding, criminal conduct while
pending sentencing, and false statements to law enforcement agents, the Pretrial Services
Officer, Probation Officer, or Court), the United States is free under this Plea Agreement
to file additional charges against Defendant or to seek a sentence that takes such conduct
into consideration by requesting the Court to apply additional adjustments or
enhancements in its Sentencing Guidelines calculations in order to increase the applicable
advisory Guidelines range, and/or by seeking an upward departure or variance from the

calculated advisory Guidelines range. Under these circumstances, the United States is

Plea Agreement - 21 UNITED STATES ATTORNEY
United States v. Williams, CR23-090-01 JHC 700 STEWART STREET, SUITE 5220
SEATTLE, WASHINGTON 98101
(206) 553-7970

So Oo JN DB Om BP W HNO =

NO Be LN DN KH BR RR eae a ea ee
YN DB wo FSP WD NY FS DT BGC TH SI DB HD BP WwW NBO KK |

Case 2:23-cr-00090-JHC Document 142 Filed 12/11/23 Page 22 of 23

free to seek such adjustments, enhancements, departures, and/or variances even if
otherwise precluded by the terms of the Plea Agreement.

17. Waiver of Appellate Rights and Rights to Collateral Attacks.
Defendant acknowledges that, by entering the guilty plea(s) required by this Plea
Agreement, Defendant waives all rights to appeal from Defendant’s conviction, and any
pretrial rulings of the Court, and any rulings of the Court made prior to entry of the
judgment of conviction. Defendant further agrees that, provided the Court imposes a
custodial sentence that is within or below the Sentencing Guidelines range (or the
statutory mandatory minimum, if greater than the Guidelines range) as determined by the
Court at the time of sentencing, Defendant waives to the full extent of the law:

a. Any right conferred by Title 18, United States Code, Section 3742,
to challenge, on direct appeal, the sentence imposed by the Court, including any fine,
restitution order, probation or supervised release conditions, or forfeiture order (if
applicable); and

b. Any right to bring a collateral attack against the conviction and
sentence, including any restitution order imposed, except as it may relate to the
effectiveness of legal representation.

This waiver does not preclude Defendant from bringing an appropriate motion
pursuant to 28 U.S.C. § 2241, to address the conditions of Defendant’s confinement or
the decisions of the Bureau of Prisons regarding the execution of Defendant’s sentence.

If Defendant breaches this Plea Agreement at any time by appealing or collaterally
attacking (except as to effectiveness of legal representation) the conviction or sentence in
any way, the United States may prosecute Defendant for any counts, including those with
mandatory minimum sentences, that were dismissed or not charged pursuant to this Plea
Agreement.

18.  Voluntariness of Plea. Defendant agrees that Defendant has entered into

this Plea Agreement freely and voluntarily, and that no threats or promises were made to

Plea Agreement - 22 UNITED STATES ATTORNEY
United States v. Williams, CR23-090-01 JHC 700 STEWART STREET, SUITE 5220
SEATTLE, WASHINGTON 98101
(206) 553-7970

CO Oo WD DR tr BR WH BB HY

bo No NO bo No No ie) ho — — — — — — — _ ae —
~l fon La) Ww NO =_— S No} CO ~ nN Nn aN Ww i) _ Se

Case 2:23-cr-00090-JHC Document 142 Filed 12/11/23 Page 23 of 23

induce Defendant to enter a plea of guilty other than the promises contained in this Plea
Agreement or set forth on the record at the change of plea hearing in this matter.

19. Statute of Limitations. [n the event this Plea Agreement is not accepted
by the Court for any reason, or Defendant breaches any of the terms of this Plea
Agreement, the statute of limitations shall be deemed to have been tolled from the date of
the Plea Agreement to: (1) thirty (30) days following the date of non-acceptance of the
Plea Agreement by the Court; or (2) thirty (30) days following the date on which a breach
of the Plea Agreement by Defendant is discovered by the United States Attorney’s
Office.

20. Completeness of Plea Agreement. The United States and Defendant
acknowledge that these terms constitute the entire Plea Agreement between the parties,
except as may be set forth on the record at the change of plea hearing in this matter. This
Plea Agreement binds only the United States Attorney’s Office for the Western District
of Washington. It does not bind any other United States Attorney’s Office or any other
office or agency of the United States, or any state or local prosecutor.

Dated this 11th day of December, 2023.

P nites RIA WILLI

MICHAEL C, NANCE

gw for Defi i

pes C
Assistant bod States Atto

Plea Agreement - 23 UNITED STATES ATTORNEY
United States yv. Williams, CR23-090-01 JHC 700 STEWART STREET, SUITE 5220
SEATTLE, WASHINGTON 98101
(206) 553-7970

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