Guilty Plea Agreement — United States v. Keesa Seannalynn Green (Eastern District of Missouri)

Summary

A Guilty Plea Agreement filed July 21, 2025 as Doc. 27 in United States of America versus Keesa Seaniya Lynn Green, Case 1:25-cr-00049-SEP, in the United States District Court for the Eastern District of Missouri. The defendant agrees to plead guilty to the indictment, which charges making a false statement to a financial institution in Count I and wire fraud, and to pay $19,966.00 in restitution. The agreed facts state that Green applied for a PPP loan with Harvest Small Business Finance on May 27, 2021, that Harvest deposited $19,966.00 on June 25, 2021, and that Green did not own or operate an eligible business. The parties agree to a base offense level of 7, with 4 levels added because the loss exceeded $15,000.00.

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“Guilty Plea Agreement — United States v. Keesa Seannalynn Green (Eastern District of Missouri).” Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/27-guilty-plea-agreement-by-usa-keesa-seaniya-lynn-green-as-to-444616c960/, SHA-256 da8f0313f6a6ecae600b1bbf9952c000524fff41f2f91509abbe118337837d62.

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Case: 1:25-cr-00049-SEP Doc. #: 27 Filed: 07/21/25 Page: 1 of 12 PageID #: 67

UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF MISSOURI
SOUTHEASTERN DMSION

UNITED STATES OF AMERICA, )
)
Plaintiff, )
) NO. 1:25 CR 49 JAR
v. )
)
KEESA SEANNALYNN GREEN, )
)
Defendant. )

GUILTY PLEA AGREEMENT

Come now the parties and hereby agree, as follows:

1. PARTIES:

The parties are the defendant Keesa Seaniya Lynn Green, represented by defense counsel

Nicole M. Johnston, and the United States of America, (hereinafter "government"), represented

by the Office of the United States Attorney for the Eastern District of Missouri. This agreement

does not, and is not intended to, bind any governmental office or agency other than the United

States Attorney for the Eastern District of Missouri. The Court is neither a party to nor bound by

this agreement.

2. GUILTY PLEA:

Pursuant to Rule ll(c){l)(A), Federal Rules of Criminal Procedure, in exchange for

defendant's voluntary plea of guilty to the indictment, the government agrees that no further

federal prosecution of the defendant will be brought in this District relative to the underlying

facts supporting the charges in the indicnnent herein, of which the government is aware at this

time. The defendant also agrees to pay $19,966.00 in restitution to the United States of America
Case: 1:25-cr-00049-SEP Doc. #: 27 Filed: 07/21/25 Page: 2 of 12 PageID #: 68

as a part of this plea.

Furthermore, the parties agree that either party may request a sentence above or below the

U.S. Sentencing Guidelines range (combination of Total Offense Level and Criminal History

Category) ultimately determined by the Court pursuant to any chapter of the Guidelines, Title 18

United States Code, Section 3553, or any other provision or rule oflaw not addressed herein. The

parties further agree that notice of any such request will be given no later than ten (10) days prior

to sentencing and that said notice shall specify the legal and factual bases for the request.

3. ELEMENTS:

The crime of making a false statement to a financial institution, as charged in Count I of

the Indictment, has three elements, which are: One, the defendant knowingly made false

statements, namely that the defendant was the owner of a qualifying small business, and that PPP

loan proceeds would be spent on permissible expenses, to a financial institution; Two, the

defendant made the false statement for the purpose of influencing the action of the financial

institution upon an application for a PPP loan; and Three, that the financial institution was backed

by the SBA at the time the statement was made.

The crime of wire fraud, as charged in Count Il of the indictment, has four elements, which

are: One, the defendant voluntarily and intentionally participated in a scheme to obtain money by

means of material false representations, namely the submission of a fraudulent PPP Loan

application, Two, the defendant did so with the intent to defraud; Three, the defendant used, or

caused to be used, an interstate wire communication, that is, use of an internet loan application

portal, in furtherance of some essential step in the scheme; and Four, the scheme affected a

financial institution.

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4.FACTS:
The parties agree that the facts in this case are as follows and that the Government would

prove these facts beyond a reasonable doubt if the case were to go to trial. These facts may be

considered as relevant conduct pursuant to Section lBl.3:

The Coronavirus Aid, Relief, and Economic Security ("CARES") Act is a federal law

that was enacted in or around March of 2020 to provide emergency financial assistance to the

millions of Americans suffering the economic impact caused by the COVID-19 pandemic. The

CARES Act authorized the Small Business Administration (SBA) to issue forgivable loans to

small businesses for job retention and certain other expenses through the Paycheck Protection

Program ("PPP").

To obtain a PPP loan, a qualifying business was required to submit a PPP loan

application, signed by an authorized representative of the business who was required to certify

that, among other things, the small business was in operation on February 15, 2020, and that

SBA loan proceeds will be used only for business-related purposes as specified in the loan

application and consistent with the Paycheck Protection Program Rules, such as retaining

workers, maintaining payroll, making mortgage interest payments, lease payments, and utility

payments. The program also required the submission of certain documents related to the identity

of the applicant and the expenses of the business, like payroll, that would be covered by the

loans.

Keesa Seaniya Lynn Green of Caruthersville, Pemiscot County Missouri was identified

as a person who had filed via an interactive internet portal, which constitutes an interstate wire

communication, a fraudulent application for a PPP loan with Harvest Small Business Finance
'

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Case: 1:25-cr-00049-SEP Doc. #: 27 Filed: 07/21/25 Page: 4 of 12 PageID #: 70

LLC (Harvest), a financial institution headquartered in Laguna Hills, California. Harvest was an

SBA approved financial institution for the PPP Loan program. Public records and investigation

showed that Green did not own or operate an eligible business and had submitted a fraudulent

Schedule C falsely stating gross income and expenses for a business that did not exist. Green had

also uploaded a copy of her photo and Missouri driver's license to the website to prove her

identity. Green applied for a loan on May 27, 2021 and Harvest deposited the proceeds,

$19,966.00 into her bank account on June 25, 2021.

As a part of this plea the defendant admits that she knowingly made false statements to a

financial institution backed by the SBA for the purpose of obtaining a loan. She also admits that

she voluntarily and intentionally participated in a scheme to obtain money, affecting a financial

institution, by means of making materially false representations via an interstate wire

communication and that she did so with the intent to defraud.

S. STATUTORY PENALTIES:

The defendant understands that the maximum possible penalty as to each Count herein is

not more than 30 years of imprisonment, a fine of not more than $1,000,000, or both a fine and

imprisonment and a term of supervised release of not more than five years.

In the event defendant is subject to any undischarged or anticipated term of imprisonment

imposed by any court, defendant has been apprised by counsel that the sentence imposed in this

case may be imposed consecutively to the undischarged or anticipated term of imprisonment.

6. U.S. SENTENCING GUIDELINES: 2024 MANUAL:

The defendant understands that this offense is affected by the U.S. Sentencing Guidelines

and the actual sentencing range is determined by both the Total Offense Level and the Criminal

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History Category. The parties agree that the following are the U.S. Sentencing Guidelines Total

Offense Level provisions that apply.

(1) Chapter 2 Offense Conduct:

(a) Base Offense Level: The parties agree that the base offense level is 7 as found

in Section 2Bl.l(a)(l).

(b) Specific Offense Characteristics: The parties agree that the following

Specific Offense Characteristics apply: 4 levels should be added pursuant to Section

2Bl.l(b)(l)(C) because the loss exceeded $15,000.00.

(2) Chapter 3 Adjustments:

(a) Acceptance of Responsibility: The parties recommend that two levels should

be deducted pursuant to Sentencing Guidelines Section 3El.l(a) because Defendant has clearly

demonstrated acceptance of responsibility.

The parties agree that if Defendant does not abide by all of the agreements made within

this document, Defendant's failure to comply is grounds for the loss of acceptance of

responsibility pursuant to Sentencing Guidelines Section 3El .1. The parties further agree that

Defendant's eligibility for a reduction pursuant to Sentencing Guidelines Section 3El .1 is based

upon the information known at the present time and that any actions of Defendant which occur or

which become known to the United States subsequent to this agreement and are inconsistent with

Defendant's acceptance of responsibility including, but not limited to criminal conduct, are

grounds for the loss of acceptance of responsibility pursuant to Sentencing Guidelines Section

3El.1. In any event, the parties agree that all of the remaining provisions of this agreement

remain valid and in full force and effect.

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(b) Other Adjustments: The parties recommend that no additional adjustments apply.

(d) Criminal History: The determination of the defendant's Criminal History Category

shall be left to the Court. Either party may challenge, before and at sentencing, the finding of the

Presentence Report as to the defendant's criminal history and the applicable category. The

defendant's criminal history is known to the defendant and is substantially available in the

Pretrial Services Report.

(e) Effect of Parties' U.S. Sentencing Guidelines Analysis: The parties agree that the

Court is not bound by the Guidelines analysis agreed to herein. The parties may not have

foreseen all applicable Guidelines. The Court may, in its discretion, apply or not apply any

Guideline despite the agreement herein and the parties shall not be permitted to withdraw from

the plea agreement.

7. WAIVER OF APPEAL AND POST-CONVICTION RIGHTS:

a. Appeal: The defendant has been fully apprised by defense counsel of the defendant's

rights concerning appeal and fully understands the right to appeal the sentence under Title 18,

United States Code, Section 3742.

(1) Non-Sentencing Issues: The parties waive all rights to appeal all non-jurisdictional,

non-sentencing issues, including, but not limited to, any issues relating to pretrial motions,

discovery and the guilty plea, the constitutionality of the statute(s) to which the defendant is

pleading guilty and whether defendant's conduct falls within the scope of the statute(s)

(2) Sentencing bsues: In the event the Court accepts the plea, accepts the U.S.

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Case: 1:25-cr-00049-SEP Doc. #: 27 Filed: 07/21/25 Page: 7 of 12 PageID #: 73

Sentencing Guidelines Total Offense Level agreed to herein, and, after determining a Sentencing

Guidelines range, sentences the defendant within or below that range, then, as part of this

agreement, the defendant hereby waives all rights to appeal all sentencing issues other than

Criminal History, but only if it affects the Base Offense Level or Criminal History Category.

Similarly, the Government hereby waives all rights to appeal all sentencing issues other than

Criminal History, provided the Court accepts the plea, adopts the agreed Total Offense Level and

sentences the defendant within or above that range.

b. Habeas Corpus: The defendant agrees to waive all rights to contest the conviction or

sentence in any post-conviction proceeding, including one pursuant to Title 28, United States

Code, Section 2255, except for claims of prosecutorial misconduct or ineffective assistance of

counsel.

c. Right to Records: The defendant waives all rights, whether asserted directly or by a

representative, to request from any department or agency of the United States, any records

pertaining to the investigation and prosecution of this case, including any records that may be

sought under the Freedom of Information Act, Title 5, United States Code, Section 522, or the

Privacy Act, Title 5, United States Code, Section 552(a).

8.0THER:

a. Disclosures Required by the United States Probation Office: The defendant agrees

to truthfully complete and sign forms as required by the United States Probation Office prior to

sentencing and consents to the release of these forms and any supporting documentation by the

United States Probation Office to the government.

b. Civil or Administrative Actions not Barred; Effect on Other Governmental
Agencies:

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Case: 1:25-cr-00049-SEP Doc. #: 27 Filed: 07/21/25 Page: 8 of 12 PageID #: 74

Nothing contained herein limits the rights and authority of the United States to take any

civil, tax, immigration/deportation or administrative action against the defendant.

c. Supervised Release: Pursuant to any supervised release term, the Court will impose

standard conditions upon the defendant and may impose special conditions related to the crime

the defendant committed. These conditions will be restrictions on the defendant to which the

defendant will be required to adhere. Violation of the conditions of supervised release resulting

in revocation may require the defendant to serve a term of imprisonment equal to the length of

the term of supervised release, but not greater than the term set forth in Title 18, United States

Code, Section 3583(e)(3), without credit for the time served after release. The defendant

understands that parole has been abolished.

d. Mandatory Special Assessment: Pursuant to Title 18, United States Code, Section

3013, the Court is required to impose a mandatory special assessment of $100 per count for a

total of $200, which the defendant agrees to pay at the time of sentencing. Money paid by the

defendant toward any restitution or fine imposed by the Court shall be first used to pay any

unpaid mandatory special assessment.

e. Possibility of Detention: The defendant may be subject to immediate detention

pursuant to the provisions of Title 18, United States Code, Section 3143.

f. Fines, Restitution and Costs of Incarceration and Supervision: The Court may

impose a fine, costs of incarceration and costs of supervision. The defendant agrees that any fine

imposed by the Court will be due and payable immediately. The defendant agrees to pay

$19,966.00 in restitution to the United States of America.

g. Forfeiture: The defendant knowingly and voluntarily waives any right, title, and interest

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in all items seized by law enforcement officials during the course of their investigation, whether

or not they are subject to forfeiture, and agrees not to contest the vesting of title of such items in

the United States. The defendant agrees to abandon [his/her] interest in all seized items and further

agrees that said items may be disposed of or destroyed by law enforcement officials in any manner

without further notice. By abandoning these items, the defendant waives any future rights to

receive additional notice, a valuation of the items, or the opportunity to submit a claim to contest

the disposition or destruction of the items that may exist under any policies or procedures of the

seizing agency(ies).

9. ACKNOWLEDGMENT AND WAIVER OF THE DEFENDANT'S RIGHTS:

In pleading guilty, the defendant acknowledges, fully understands and hereby waives his

rights, including but not limited to: the right to plead not guilty to the charges; the right to be

tried by a jury in a public and speedy trial; the right to file pretrial motions, including motions to

suppress or exclude evidence; the right at such trial to a presumption of innocence; the right to

require the government to prove the elements of the offenses charged against the defendant

beyond a reasonable doubt; the right not to testify; the right not to present any evidence; the right

to be protected from compelled self-incrimination; the right at trial to confront and cross-

examine adverse witnesses; the right to testify and present evidence and the right to compel the

attendance of witnesses. The defendant further understands that by this guilty plea, the

defendant expressly waives all the rights set forth in this paragraph.

The defendant fully understands that the defendant has the right to be represented by

counsel, and if necessary, to have the Court appoint counsel at trial and at every other stage of

the proceeding. The defendant's counsel has explained these rights and the consequences of the

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76

waiver of these rights. The defendant fully understands that, as a result of the guilty plea, no trial

will, in fact, occur and that the only action remaining to be taken in this case is the imposition of

the sentence.

The defendant is fully satisfied with the representation received from defense counsel.

The defendant has reviewed the government's evidence and discussed the government's case and

all possible defenses and defense witnesses with defense counsel. Defense counsel has

completely and satisfactorily explored all areas which the defendant has requested relative to the

government's case and any defenses.

The terms and conditions contained in this stipulation constitute the only plea offer which

has been tendered to the defendant by the Government herein. Defendant has fully discussed the

terms and conditions of the offer with counsel and the defendant understands and agrees to the

same.

10. VOLUNTARY NATURE OF THE GUILTY PLEA AND PLEA AGREEMENT:

This document constitutes the entire agreement between the defendant and the

government, and no other promises or inducements have been made, directly or indirectly, by

any agent of the government, including any Department of Justice attorney, concerning any plea

to be entered in this case. In addition, the defendant states that no person has, directly or

indirectly, threatened or coerced the defendant to do or refrain from doing anything in

connection with any aspect of this case, including entering a plea of guilty.

The defendant acknowledges having voluntarily entered into both the plea agreement and

the guilty plea. The defendant further acknowledges that this guilty plea is made of the

defendant's own free will and that the defendant is, in fact, guilty.
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11. CONSEQUENCES OF POST-PLEA MISCONDUCT:

After pleading guilty and before sentencing, if defendant commits any crime, other than

minor traffic offenses, violates any conditions of release that results in revocation, violates any

term of this guilty-plea agreement, intentionally provides misleading, incomplete or untruthful

information to the U.S. Probation Office or fails to appear for sentencing, the United States, at its

option may be released from its obligations under this agreement. The Government may also, in

its discretion, proceed with this agreement and may advocate for any sentencing position

supported by the facts, including but not limited to obstruction of justice and denial of

acceptance ofresponsibility.

12. NO RIGHT TO WITHDRAW GUILTY PLEA:

Pursuant to Rule 11 ( c) and (d), Federal Rules of Criminal Procedure, the defendant

understands that there will be no right to withdraw the plea entered under this agreement, except

where the Court rejects those portions of the plea agreement which deal with charges the

government agrees to dismiss or not to bring.

Date
~r<L
Tim J. Willi~ 62428MO
Assistant United States Attorney
555 Independence Street, Suite 3000
Cape Girardeau, Missouri 63703

Date ~§.~~
Defendant
Case: 1:25-cr-00049-SEP Doc. #: 27 Filed: 07/21/25 Page: 12 of 12 PageID #:
78

Date Nicole M. Johnston
Law Office of Nicole Johnston, LLC
PO Box440143
St. Louis, Missouri 63144

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