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Stipulation as to Restitution Amount — United States v. Jean Renald Fleuridor (Southern District of Florida)

Summary

A Joint Stipulation as to Restitution Amount entered April 26, 2022 as Document 140 in United States of America versus Jean Renald Fleuridor, Case No. 21-20262-SINGHAL, in the United States District Court for the Southern District of Florida. It states that the total restitution owed by the defendant under the Mandatory Victims Restitution Act of 1996 is $11,342,932.50, joint with co-defendants. It lists payments to the Small Business Administration ($3,093,161.97), Cross River Bank ($2,411,744.42), Celtic Bank ($172,360.56), Kabbage ($3,940,000.35), Bank of America ($326,107.71) and USAA Bank. During incarceration the defendant must pay 50% of UNICOR wages or a minimum of $25.00 per quarter, and after release 10% of monthly gross earnings. It is signed by Assistant United States Attorney Brooke Watson and by Mitchell A. Stone and Omar Lopez.

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“Stipulation as to Restitution Amount — United States v. Jean Renald Fleuridor (Southern District of Florida).” Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/140-stipulation-as-to-restitution-amount-by-usa-as-to-jean-renal-fc0ffa87c5/, SHA-256 6062f0bcfe5fc8078c9de0a19fd3820d7fa7e7a15ac733f2904b82436316375e.

Full text

Case 1:21-cr-20262-AHS Document 140 Entered on FLSD Docket 04/26/2022 Page 1 of 6




                            UNITED STATES DISTRICT COURT
                            SOUTHERN DISTRICT OF FLORIDA

                                CASE NO. 21-20262-SINGHAL

  UNITED STATES OF AMERICA


  v.

  JEAN RENALD FLEURIDOR,

                  Defendant.

  ____________________________________/

                  JOINT STIPULATION AS TO RESTITUTION AMOUNT

              The United States of America, by and through the undersigned Assistant United

  States Attorney, hereby files this Joint Stipulation as to Restitution Amount.

         1.       Pursuant to the Mandatory Victims Restitution Act of 1996, the total amount

  of restitution owed by the defendant in the above captioned matter is $11,342,932.50, joint

  and severable with his co-defendants. The Restitution payments should be made payable to

  Clerk, United States Courts, and forwarded to:

                                    U.S. CLERK’S OFFICE
                                ATTN: FINANCIAL SECTION
                             400 N MIAMI AVENUE, ROOM 8N09
                                      MIAMI, FL 33128

         2.       The Clerk’s office shall disburse the Restitution to the victims via payments

  made payable to the following victims, and their successors or assignees, joint and several

  with his co-defendants:
Case 1:21-cr-20262-AHS Document 140 Entered on FLSD Docket 04/26/2022 Page 2 of 6




        a. Three-million, ninety-three thousand, one hundred and sixty-one dollars and ninety-

  seven cents ($3,093,161.97) payable to The Small Business Administration, SBA/DFC and

  mailed to:


                                            SBA/DFC
                                 721 19th St, 3rd Floor, Room 301
                                        Denver, CO 80202

  RE:

           b.     Two million, four-hundred and eleven thousand, seven-hundred and forty-four

  dollars and forty-two cents ($2,411,744.42) made payable to Cross River Bank and mailed

  to:

                                                 `
                                        Cross River Bank
                                     400 Kelby St, 14th floor
                                       Fort Lee, NJ 07024
                                     Attention: Paola Lazarte


  RE:                           Cross River Bank     25174774-00
                                Cross River Bank     36520278-05
                                Cross River Bank     17741974-06
                                Cross River Bank     49438174-08
                                Cross River Bank     25214074-04

           c.     One hundred seventy-two thousand, three hundred and sixty dollars and fifty-

  six cents ($172,360.56) made payable to Celtic Bank and mailed to:

                                            Celtic Bank
                                   268 S. State Street, Suite 300
                                    Salt Lake City, Utah 84111
                                    Attention: Nissen Liddiard

  RE:                                 Celtic Bank    33511674-05
                                      Celtic Bank    63181674-07
                                      Celtic Bank    32162774-00
                                      Celtic Bank    53595274-10
                                      Celtic Bank    67639378-03
                                      Celtic Bank    40577778-07
                                      Celtic Bank    44454173-05
Case 1:21-cr-20262-AHS Document 140 Entered on FLSD Docket 04/26/2022 Page 3 of 6




                                    Celtic Bank   19089374-10
                                    Celtic Bank   69048773-02
                                    Celtic Bank   62317174-03
                                    Celtic Bank   47299374-08

        d.     Three million, nine hundred and forty thousand dollars and thirty-five cents

  ($3,940,000.35) made payable to Kabbage and mailed to:


                                         Kabbage
                                  730 Peachtree Street NE
                                    Atlanta, GA 30308
                                   Attn: Caty Bergmark

  RE:                               Kabbage       43820680-00
                                    Kabbage       74062879-03
                                    Kabbage       35626080-10
                                    Kabbage       50717280-05
                                    Kabbage       53145380-02
                                    Kabbage       69684379-08
                                    Kabbage       65019579-07
                                    Kabbage       43052880-03
                                    Kabbage       21129280-10
                                    Kabbage       87540479-02
                                    Kabbage       87050279-00
                                    Kabbage       69906479-08
                                    Kabbage       54052279-06

        e.     Three-hundred and twenty-six thousand, one-hundred and seven dollars and

  seventy-once cents ($326,107.71) made payable to Bank of America and mailed to:

                                       Bank of America
                                   Attn: Sheena Travis-Bell
                                    9000 Southside Blvd
                                          Bldg. 600
                                  Mail Code: FL9-600-02-15
                                   Jacksonville, FL 32256

        f.     One million, two-hundred and twenty-one thousand, eight hundred and

  twenty-eight dollars and eight cents ($1,399,557.49) made payable to USAA Bank and mailed

  to:
Case 1:21-cr-20262-AHS Document 140 Entered on FLSD Docket 04/26/2022 Page 4 of 6




                                         USAA Bank
                                   9800 Fredericksburg Road,
                                   San Antonio, Texas 78288


         4.     During the period of incarceration, payment shall be made as follows: (1) if the

  defendant earns wages in a Federal Prison Industries (UNICOR) job, then the defendant must

  pay 50% of wages earned toward the financial obligations imposed by the Judgment in a

  Criminal Case; (2) if the defendant does not work in a UNICOR job, then the defendant must

  pay a minimum of $25.00 per quarter toward the financial obligations.

         5.     Upon release from incarceration, the defendant shall pay restitution at the rate

  of 10% of monthly gross earnings, until such time as the Court may alter that payment

  schedule in the interests of justice. The U.S. Bureau of Prisons, U.S. Probation Office and

  U.S. Attorney's Office shall monitor the payment of restitution and report to the Court any

  material change in the defendant's ability to pay. The restitution shall be made payable to

  Clerk, United States Courts, and forwarded to:

                                      U.S. CLERK’S OFFICE
                                  ATTN: FINANCIAL SECTION
                               400 N MIAMI AVENUE, ROOM 8N09
                                        MIAMI, FL 33128

         The Clerk’s office shall disburse the Restitution to the victims as stated in paragraph
  one.
Case 1:21-cr-20262-AHS Document 140 Entered on FLSD Docket 04/26/2022 Page 5 of 6




         6.     The restitution amount is due immediately. Any partial restitution payments

  made by the Defendant do not preclude the government from using any other anticipated or

  unexpected financial gains, assets or income of the defendant to satisfy the restitution

  obligation.   Defendant agrees that he will not sell, hide, waste, encumber, destroy, or

  otherwise devalue any asset for the purpose of evading or defeating his restitution obligation

  that may be imposed upon him by the Court.

                                                    Respectfully submitted,

                                                    JUAN ANTONIO GONZALEZ
                                                    UNITED STATES ATTORNEY


                                             By:    /s/Brooke Watson
                                                    Brooke Watson
                                                    Assistant United States Attorney
                                                    Court No. A5501844
                                                    United States Attorney’s Office
                                                    99 N.E. 4th Street, Suite 400
                                                    Miami, FL 33132-2111
                                                    Telephone: (305) 961-9070
                                                    Email: brooke.watson@usdoj.gov


                                                    /s/ Mitchell A. Stone
                                                    Mitchell A. Stone, Esq.
                                                    Board Certified Criminal Trial Law
                                                    Mitchell A. Stone, P.A.
                                                    1830 Atlantic Blvd.
                                                    Jacksonville, Florida 32207
                                                    Telephone: 904.396.3335

                                                    /s/ Omar Lopez
                                                    Omar Lopez, Esq.
                                                    848 Brickell Ave STE 800,
                                                    Miami, FL 33131
                                                    Telephone: 305-789-4430
Case 1:21-cr-20262-AHS Document 140 Entered on FLSD Docket 04/26/2022 Page 6 of 6




                             CERTIFICATE OF SERVICE

         I HEREBY CERTIFY that on April 26, 2022, I electronically filed the foregoing

   with the Clerk of the Court using CM/ECF.

                                         /s/ Brooke Watson
                                         Brooke Watson
                                         Assistant United States Attorney


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