Plea Agreement, United States of America v. Lester John Parker, Jr.
Summary
Plea agreement in United States of America v. Lester John Parker, Jr., Case No. 2:24-cr-135-SPC-KCD, United States District Court for the Middle District of Florida, Fort Myers Division, filed June 30, 2025 as Document 42. Parker agrees to plead guilty to Counts One, Six, Seven, Eight, and Twelve of the Indictment, which charge Conspiracy to Commit Wire Fraud, Wire Fraud, Access Device Fraud, Aggravated Identity Theft and Conspiracy to Commit Money Laundering; the remaining counts are to be dismissed at sentencing. The forfeiture terms include an order of approximately $911,118.70, which the agreement says represents proceeds the defendant personally obtained. The factual basis states that on or about June 11, 2021, approximately $12,757.86 of Faith Works Marketing's fraudulently-obtained PPP proceeds went to accounts in the names of 14 sham employees.
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“Plea Agreement, United States of America v. Lester John Parker, Jr.”
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Case 2:24-cr-00135-SPC-DNF Document 42 Filed 06/30/25 Page 1 of 20 PageID 90
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UNITED STATES DISTRJCT COURT
MIDDLE DISTRICT OF FLORJDA
FORT MYERS DIVISION
UNITED STATES OF AMERlCA
V.
CASE NO. 2:24-cr-135-SPC-KCD
LESTER JOHN PARKER, JR.
PLEA AGREEMENT
Pursuant to Fed. R. Crim. P. l l(c), the United States of America, by Gregory
W. Kehoe, United States Attorney for the Middle District of Florida, and the
defendant, Lester John Parker, Jr., and the attorney for the defendant, Roy W. Foxall,
Esq., mutually agree as follows:
A. Particularized Terms
1. Count(s) Pleading To
The defendant shall enter a plea of guilty to Counts One, Six, Seven,
Eight, and Twelve of the Indictment. Count One charges the defendant with
Conspiracy to Commit Wire Fraud, in violation of 18 U.S.C. § 1349; Count Six
charges the defendant with Wire Fraud, in violation of 18 U.S.C. § 1343; Count Seven
charges the defendant with Access Device Fraud, in violation of 18 U.S.C.
§ 1029(a)(2); Count Eight charges the defendant with Aggravated Identity Theft, in
violation of 18 U.S.C. § 1028A(a)(2); and Count Twelve charges the defendant with
Conspiracy to Commit Money Laundering, in violation of 18 U.S.C. § 1956(h).
Defendant's Initials£
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2. Minimum and Maximum Penalties
Counts One, Six, and Twelve each carry a maximum sentence of twenty
years imprisonment, a fine ofup to $250,000.00 (or twice the gross gain caused by the
offense, or twice the gross loss caused by the offense, whichever is greater), a term of
supervised release of not more than three years, and a special assessment of $100.00.
Count Seven carries a maximum sentence of ten years imprisonment, a
fine ofup to $250,000 (or twice the gross gain caused by the offense, or twice the gross
loss caused by the offense, whichever is greater), a term of supervised release of not
more than three years, and a special assessment of $100.
Count Eight is punishable by a mandatory nurumum term of
imprisonment of two years consecutive to any other term of imprisonment imposed, a
fine ofup to $250,000 (or twice the gross gain caused by the offense, or twice the gross
loss caused by the offense, whichever is greater), a term of supervised release of not
more than one year, and a special assessment of $100
With respect to certain offenses, the Court shall order the defendant to
make restitution to any victim of the offense(s), and with respect to other offenses, the
Court may order the defendant to make restitution to any victim of the offense(s), or
to the community, as set forth below.
Defendant's Initials t/!____ 2
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3. Elements of the Offense(s)
The defendant acknowledges understanding the nature and elements of
the offense(s) with which defendant has been charged and to which defendant is
pleading guilty.
The elements of Count One are as follows:
First: two or more persons, in some way or manner, agreed to try
to accomplish a common and unlawful plan to commit Wire
Fraud (in violation of 18 U.S.C. § 1343) as charged in the
Information; and
Second: the defendant knew the unlawful purpose of the plan and
willfully joined in it.
The elements of Count Six are as follows:
First: the defendant knowingly devised or participated in a
scheme to defraud someone by using false or fraudulent
pretenses, representations, or promises;
Second: the false pretenses, representations, or promises were about
a material fact;
Three: the defendant acted with the intent to defraud; and
the defendant transmitted or caused to be transmitted by
wire some communication in interstate commerce to help
carry out the scheme to defraud.
The elements of Count Seven are as follows:
First: the defendant knowingly used one or more unauthorized
access devices;
Defendant's Initials£. 3
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Second: the defendant, during a 12-month period, obtained a thing
or things of value totaling $1,000 or more as a result of such
use of unauthorized access devices;
Third: the defendant acted with the intent to defraud or deceive;
and
Fourth: the defendant's conduct affected interstate or foreign
commerce.
The elements of Count Eight are as follows:
•the defendant knowingly transferred, possessed, or used
another person's means of identification;
Second: without lawful authority; and
Third: during and in relation to an eligible felony (including Access
Device Fraud).
The elements of Count Twelve are as follows:
First: two or more people agreed to try to accomplish a common
and unlawful plan to violate 18 U.S.C. § 1956(a)(l)(A)(i) or
18 U.S.C . § 1956(a)(l)(B)(i); and
Second: the defendant knew about the plan's unlawful purpose and
willfully joined in it.
4. Count(s) Dismissed
At the time of sentencing, the remaining count(s) against the defendant,
Counts Two, Three, Four, Five, Nine, Ten, Eleven, Thirteen, Fourteen, and Fifteen
Indictment, will be dismissed pursuant to Fed. R. Crim. P. 1l(c)(l)(A).
Defendant's Initials 21{_ 4
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5. No Further Charges
If the Court accepts this plea agreement, the United States Attorney's
Office for the Middle District of Florida agrees not to charge defendant with
committing any other federal criminal offenses known to the United States Attorney's
Office at the time of the execution of this agreement, related to the conduct giving rise
to this plea agreement.
6. Mandatory Restitution to Victim of Offense of Conviction
Pursuant to 18 U.S.C. § 3663A(a) and (b), defendant agrees to make
restitution in this matter.
7. Guidelines Sentence
Pursuant to Fed. R. Crim. P. ll(c)(l)(B), the United States will
recommend to the Court that the defendant be sentenced within the defendant's
applicable guidelines range as determined by the Court pursuant to the United States
Sentencing Guidelines, as adjusted by any departure the United States has agreed to
recommend in this plea agreement. The parties understand that such a
recommendation is not binding on the Court and that, if it is not accepted by this
Court, neither the United States nor the defendant will be allowed to withdraw from
the plea agreement, and the defendant will not be allowed to withdraw from the plea
of guilty.
8. Acceptance of Responsibility - Three Levels
At the time of sentencing, and in the event that no adverse information
is received suggesting such a recommendation to be unwarranted, the United States
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will recommend to the Court that the defendant receive a two-level downward
adjustment for acceptance of responsibility, pursuant to USSG § 3El. l(a). The
defendant understands that this recommendation or request is not binding on the
Court, and if not accepted by the Court, the defendant will not be allowed to withdraw
from the plea.
Further, at the time of sentencing, if the defendant's offense level prior to
operation of subsection (a) is level 16 or greater, and if the defendant complies with
the provisions of USSG § 3E 1.1 (b) and all terms of this Plea Agreement, including but
not limited to, the timely submission of the financial affidavit referenced in Paragraph
B.5., the United States agrees to file a motion pursuant to USSG § 3El.l(b) for a
downward adjustment of one additional level. The defendant understands that the
determination as to whether the defendant has qualified for a downward adjustment
of a third level for acceptance of responsibility rests solely with the United States
Attorney for the Middle District of Florida, and the defendant agrees that the
defendant cannot and will not challenge that determination, whether by appeal,
collateral attack, or otherwise.
9. Forfeiture of Assets
The defendant agrees to forfeit to the United States immediately and
voluntarily any and all assets and property, or portions thereof, subject to forfeiture,
pursuant to 18 U.S.C. §§ 981(a)(l)(C), 982(a)(l), 982(a)(2)(B), 1029(c)(l)(C), and 28
U .S.C. § 2461(c), whether in the possession or control of the United States, the
defendant or defendant's nominees. The assets to be forfeited specifically include, but
Defendant's Initials ff£_ 6
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are not limited to, an order of forfeiture in the amount of approximately $911,118.70,
which represents proceeds the defendant personally obtained as the result of the
commission of the offense(s) to which the defendant is pleading guilty. The defendant
acknowledges and agrees that: (1) the defendant obtained this amount as a result of
the commission of the offense(s), and (2) as a result of the acts and omissions of the
defendant, the proceeds have been transferred to third parties and cannot be located
by the United States upon the exercise of due diligence. Therefore, the defendant
agrees that, pursuant to 21 U.S.C. § 853(p), the United States is entitled to forfeit any
other property of the defendant (substitute assets), up to the amount of proceeds the
defendant obtained, as the result of the offense(s) of conviction. The defendant further
consents to, and agrees not to oppose, any motion for substitute assets filed by the
United States up to the amount of proceeds obtained from commission of the offense(s)
and consents to the entry of the forfeiture order into the Treasury Offset Program. The
defendant agrees that forfeiture of substitute assets as authorized herein shall not be
deemed an alteration of the defendant's sentence.
The defendant additionally agrees that since the criminal proceeds have
been transferred to third parties and cannot be located by the United States upon the
exercise of due diligence, the preliminary and final orders of forfeiture should
authorize the United States Attorney's Office to conduct discovery (including
depositions, interrogatories, requests for production of documents, and the issuance of
subpoenas), pursuant to Rule 32.2(b)(3) of the Federal Rules of Criminal Procedure,
to help identify, locate, and forfeit substitute assets.
Defendant's Initials # 7
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The defendant also agrees to waive all constitutional, statutory, and
procedural challenges (including direct appeal, habeas corpus, or any other means) to
any forfeiture carried out in accordance with this Plea Agreement on any grounds,
including that the forfeiture described herein constitutes an excessive fine, was not
properly noticed in the charging instrument, addressed by the Court at the time of the
guilty plea, announced at sentencing, or incorporated into the judgment.
The defendant admits and agrees that the conduct described in the
Factual Basis below provides a sufficient factual and statutory basis for the forfeiture
of the property sought by the government. Pursuant to Rule 32.2(b)(4), the defendant
agrees that the preliminary order of forfeiture will satisfy the notice requirement and
will be final as to the defendant at the time it is entered. In the event the forfeiture is
omitted from the judgment, the defendant agrees that the forfeiture order may be
incorporated into the written judgment at any time pursuant to Rule 36.
The defendant agrees to take all steps necessary to identify and locate all
substitute assets and to transfer custody of such assets to the United States before the
defendant's sentencing. To that end, the defendant agrees to make a full and complete
disclosure of all assets over which defendant exercises control, including all assets held
by nominees, to execute any documents requested by the United States to obtain from
any other parties by lawful means any records of assets owned by the defendant, and
to consent to the release of the defendant's tax returns for the previous five years . The
defendant agrees to be interviewed by the government, prior to and after sentencing,
regarding such assets. The defendant further agrees to be polygraphed on the issue of
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assets, if it is deemed necessary by the United States. The defendant agrees that
Federal Rule of Criminal Procedure 11 and USSG § lBl.8 will not protect from
forfeiture assets disclosed by the defendant as part of the defendant's cooperation.
The defendant agrees to take all steps necessary to assist the government
in obtaining clear title to any substitute assets before the defendant's sentencing. In
addition to providing full and complete information about substitute assets, these steps
include, but are not limited to, the surrender of title, the signing of a consent decree of
forfeiture, and signing of any other documents necessary to effectuate such transfers.
Forfeiture of the defendant's assets shall not be treated as satisfaction of
any fine, restitution, cost of imprisonment, or any other penalty the Court may impose
upon the defendant in addition to forfeiture.
The defendant agrees that, in the event the Court determines that the
defendant has breached this section of the Plea Agreement, the defendant may be
found ineligible for a reduction in the Guidelines calculation for acceptance of
responsibility and substantial assistance, and may be eligible for an obstruction of
justice enhancement.
The defendant agrees that the forfeiture provisions of this plea agreement
are intended to, and will, survive the defendant, notwithstanding the abatement of any
underlying criminal conviction after the execution of this agreement. The forfeitability
of any particular property pursuant to this agreement shall be determined as if the
defendant had survived, and that determination shall be binding upon defendant's
Defendant's Initials~ 9
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heirs, successors and assigns until the agreed forfeiture, including the forfeiture of any
substitute assets, is final.
B. Standard Terms and Conditions
1. Restitution. Special Assessment and Fine
The defendant understands and agrees that the Court, in addition to or
in lieu of any other penalty, shall order the defendant to make restitution to any victim
of the offense(s), pursuant to 18 U .S.C. § 3663A, for all offenses described in 18 U.S.C.
§ 3663A(c)(l); and the Court may order the defendant to make restitution to any victim
of the offense(s), pursuant to 18 U.S.C. § 3663, including restitution as to all counts
charged, whether or not the defendant enters a plea of guilty to such counts, and
whether or not such counts are dismissed pursuant to this agreement. The defendant
further understands that compliance with any restitution payment plan imposed by the
Court in no way precludes the United States from simultaneously pursuing other
statutory remedies for collecting restitution (28 U .S.C. § 3003(b)(2)), including, but
not limited to, garnishment and execution, pursuant to the Mandatory Victims
Restitution Act, in order to ensure that the defendant's restitution obligation is
satisfied.
On each count to which a plea of guilty is entered, the Court shall impose
a special assessment pursuant to 18 U.S.C. § 3013. The defendant understands that
this agreement imposes no limitation as to fine.
Defendant's Initials 1il2_
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2. Supervised Release
The defendant understands that the offenses to which the defendant is
pleading provides for imposition of a term of supervised release upon release from
imprisonment, and that, if the defendant should violate the conditions of release, the
defendant would be subject to a further term of imprisonment.
3. Immigration Consequences of Pleading Guilty
The defendant has been advised and understands that, upon conviction,
a defendant who is not a United States citizen may be removed from the United States,
denied citizenship, and denied admission to the United States in the future.
4. Sentencing Information
The United States reserves its right and obligation to report to the Court
and the United States Probation Office all information concerning the background,
character, and conduct of the defendant, to provide relevant factual information,
including the totality of the defendant's criminal activities, if any, not limited to the
count(s) to which defendant pleads, to respond to comments made by the defendant
or defendant's counsel, and to correct any misstatements or inaccuracies. The United
States further reserves its right to make any recommendations it deems appropriate
regarding the disposition of this case, subject to any limitations set forth herein, if any.
5. Financial Disclosures
Pursuant to 18 U.S.C. § 3664(d)(3) and Fed. R. Crim. P. 32(d)(2)(A)(ii),
the defendant agrees to complete and submit to the United States Attorney's Office
within 30 days of execution of this agreement an affidavit reflecting the defendant's
Defendant's Initials£ 11
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financial condition. The defendant prormses that his financial statement and
disclosures will be complete, accurate and truthful and will include all assets in which
he has any interest or over which the defendant exercises control, directly or indirectly,
including those held by a spouse, dependent, nominee or other third party. The
defendant further agrees to execute any documents requested by the United States
needed to obtain from any third parties any records of assets owned by the defendant,
directly or through a nominee, and, by the execution of this Plea Agreement, consents
to the release of the defendant's tax returns for the previous five years. The defendant
similarly agrees and authorizes the United States Attorney's Office to provide to, and
obtain from, the United States Probation Office, the financial affidavit, any of the
defendant's federal, state, and local tax returns, bank records and any other financial
information concerning the defendant, for the purpose of making any
recommendations to the Court and for collecting any assessments, fines, restitution,
or forfeiture ordered by the Court. The defendant expressly authorizes the United
States Attorney's Office to obtain current credit reports in order to evaluate the
defendant's ability to satisfy any financial obligation imposed by the Court.
6. Sentencing Recommendations
It is understood by the parties that the Court is neither a party to nor
bound by this agreement. The Court may accept or reject the agreement, or defer a
decision until it has had an opportunity to consider the presentence report prepared by
the United States Probation Office. The defendant understands and acknowledges
that, although the parties are permitted to make recommendations and present
Defendant's Initials ~ 12
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arguments to the Court, the sentence will be determined solely by the Court, with the
assistance of the United States Probation Office. Defendant further understands and
acknowledges that any discussions between defendant or defendant's attorney and the
attorney or other agents for the government regarding any recommendations by the
government are not binding on the Court and that, should any recommendations be
rejected, defendant will not be permitted to withdraw defendant's plea pursuant to this
plea agreement. The government expressly reserves the right to support and defend
any decision that the Court may make with regard to the defendant's sentence, whether
or not such decision is consistent with the government's recommendations contained
herein.
7. Defendant's Waiver of Right to Appeal the Sentence
The defendant agrees that this Court has jurisdiction and authority to
impose any sentence up to the statutory maximum and expressly waives the right to
appeal defendant's sentence on any ground, including the ground that the Court erred
in determining the applicable guidelines range pursuant to the United States
Sentencing Guidelines, except (a) the ground that the sentence exceeds the defendant's
applicable guidelines range as determined by the Court pursuant to the United States
Sentencing Guidelines; (b) the ground that the sentence exceeds the statutory
maximum penalty; or (c) the ground that the sentence violates the Eighth Amendment
to the Constitution; provided, however, that if the government exercises its right to
appeal the sentence imposed, as authorized by 18 U.S.C. § 3742(b), then the defendant
Defendant's Initia!Jf}_ 13
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is released from his waiver and may appeal the sentence as authorized by 18 U.S.C. §
3742(a).
8. Middle District of Florida Agreement
It is further understood that this agreement is limited to the Office of the
United States Attorney for the Middle District of Florida and cannot bind other
federal, state, or local prosecuting authorities, although this office will bring
defendant's cooperation, if any, to the attention of other prosecuting officers or others,
if requested.
9. Filing of Agreement
This agreement shall be presented to the Court, in open court or in
camera, in whole or in part, upon a showing of good cause, and filed in this cause, at
the time of defendant's entry of a plea of guilty pursuant hereto.
10. Voluntariness
The defendant acknowledges that defendant is entering into this
agreement and is pleading guilty freely and voluntarily without reliance upon any
discussions between the attorney for the government and the defendant and
defendant's attorney and without promise of benefit of any kind (other than the
concessions contained herein), and without threats, force, intimidation, or coercion of
any kind. The defendant further acknowledges defendant's understanding of the
nature of the offense or offenses to which defendant is pleading guilty and the elements
thereof, including the penalties provided by law, and defendant's complete satisfaction
with the representation and advice received from defendant's undersigned counsel (if
Defendant's Initials ';;l/(J 14
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any). The defendant also understands that defendant has the right to plead not guilty
or to persist in that plea if it has already been made, and that defendant has the right
to be tried by a jury with the assistance of counsel, the right to confront and cross-
examine the witnesses against defendant, the right against compulsory self-
incrimination, and the right to compulsory process for the attendance of witnesses to
testify in defendant's defense; but, by pleading guilty, defendant waives or gives up
those rights and there will be no trial. The defendant further understands that if
defendant pleads guilty, the Court may ask defendant questions about the offense or
offenses to which defendant pleaded, and if defendant answers those questions under
oath, on the record, and in the presence of counsel (if any), defendant's answers may
later be used against defendant in a prosecution for perjury or false statement. The
defendant also understands that defendant will be adjudicated guilty of the offenses to
which defendant has pleaded and, if any of such offenses are felonies, may thereby be
deprived of certain rights, such as the right to vote, to hold public office, to serve on a
jury, or to have possession of firearms.
11. Factual Basis
Defendant is pleading guilty because defendant is in fact guilty. The
defendant certifies that defendant does hereby admit that the facts set forth below are
true, and were this case to go to trial, the United States would be able to prove those
specific facts and others beyond a reasonable doubt.
Defendant's Initials 'if_ 15
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FACTS
Wire Fraud
Between approximately May 2020 and December 2021, the defendant
Lester John Parker, Jr., knowingly conspired with others-including David Kendrelle
Sims ("Sims") separately charged in M.D. Fla. Case No. 2:24-cr-90-SPC-NPM-to
defraud Small Business Administration (SBA)-approved lenders participating in the
Paycheck Protection Program (PPP) by electronically submitting materially false and
fraudulent PPP loan application packages using, among other things, interstate wire
communications.
During and in furtherance of the conspiracy, the defendant, among other
things, would prepare PPP applications which deliberately included materially false
and fraudulent representations concerning the PPP applicant's average monthly
payroll and/ or number of employees, which would later be electronically submitted
to SBA-approved PPP lenders, seeking forgivable PPP loans. The PPP application
packages would also include false and fictious IRS filings created by the defendant-
such as bogus IRS Forms 1040 (Schedule C) and bogus IRS Forms 940 in the names
of PPP applicants-and false and fictitious bank statements created by Sims, meant to
support the inflated loan amounts being sought. The fraudulent loan application
packages submitted to PPP lenders by the defendant would often induce and cause
PPP lenders to approve fraudulent PPP applications, resulting in PPP lenders
electronically depositing loan funds into bank accounts controlled by PPP applicants,
including the defendant.
Defendant's I n i t i ~ 16
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For example, in early-April 2021, the defendant personally prepared PPP
loan application seeking $663,833.00 for a company he owned called Faith Works
Marketing, LLC ("Faith Works Marketing"). In the application, the defendant
claimed that Faith Works Marketing had 38 employees and had a gross income
exceeding $4 million in 2019. In truth, as the defendant was aware, both claims were
false: Faith Works Marketing had no gross income in 2019 and had no genuine
employees. In support of the fraudulent PPP application, the defendant created a fake
2019 IRS Form 1040 (Schedule C) purportedly associated with Faith Works
Marketing (claiming more than $4 million in gross income for the year) and a fake
2019 IRS Form 940 for Faith Works Marketing (claiming more than $3 million in total
payments to employees for the year).
In further support of the fraudulent PPP application, the defendant
directed Sims to falsify a JPMorgan Chase Bank ("Chase Bank") account statement
for Faith Works Marketing which purported to be the company's February 2020 bank
statement. The fictitious account statement, which was made to appear like a genuine
Chase Bank statement, represented that Faith Works Marketing had a beginning
monthly balance of $455,895.38 and an ending balance of $363,682.37 in its Chase
Bank account for the month of February 2020. The fictitious statement noted
$148,822.16 in deposits and additions to the account, and -$241,018.17 in ATM and
debit card withdrawals for month of February 2020. In truth, Faith Works
Marketing's Chase Bank account ending in-5957 did not even exist in February 2020,
as the account was notnened by the defendant until June 2020.
Defendant's InitialstrJ 17
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On or about April 9, 2021, as charged in Count Six of the Indictment, the
defendant electronically submitted Faith Works Marketing's false and fraudulent PPP
loan application package-which included the application, fake IRS documents, and
fake bank statement-from his residence in the Middle District of Florida to Lender
#3 through servers located outside the State of Florida. Induced by the false, fictitious,
and fraudulent documents and representations made in connection with Faith Works
Marketing's PPP loan application, Lender# 3 approved Faith Works Marketing's
application and, on or about April 14, 2021, disbursed $663,833.00 into a Chase Bank
account ending in -5957 controlled by the defendant.
In total, during the wire fraud conspiracy outlined in Count One of the
Indictment, conspirators caused dozens of false and fraudulent PPP loan application
packages to be filed with a variety of SBA-approved lenders, resulting in over $2.5
million in fraudulent PPP disbursements. During the conspiracy, the defendant
personally obtained approximately $911,118.33 in fraudulent PPP disbursements in
connection with six different fraudulent PPP loan applications submitted to four
different PPP lenders.
Money Laundering
During the conspiracy, the defendant and Sims also utilized a payroll
processing company to help launder Faith Works Marketing's fraudulently obtained
PPP proceeds. Following disbursement of Faith Works Marketing's PPP funds by
Lender #3, the defendant directed Sims to provide a list of sham employees, bank
account information, and salary payroll instructions to an online payroll processing
Defendant's Initials 7ff!.___ 18
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company on behalf of Faith Works Marketing. On or about June 11, 2021, at the
request of conspirators, the payroll processing company disbursed approximately
$12,757.86 of Faith Works Marketing's fraudulently-obtained PPP proceeds to bank
accounts in the names of 14 sham employees via interstate financial transaction.
Access Device Fraud and Aggravated Identity Theft
On or about June 12, 2021, in furtherance of the conspiracy, Sims used at
least four debit cards associated with sham employee bank accounts (each of which
was possessed and used without the lawful authorization of the relevant named account
holder) at an ATM in Lehigh Acres, Florida, to withdraw a total of approximately
$2,000 in Faith Works Marketing's bogus payroll disbursements. One such debit card
utilized was issued in the name of T .D., whose personal identification information
was used during the offense without lawful authorization.
12. Entire Agreement
This plea agreement constitutes the entire agreement between the
government and the defendant with respect to the aforementioned guilty plea and no
other promises, agreements, or representations exist or have been made to the
defendant or defendant's attorney with regard to such guilty plea.
Defendant's Initial;£_ 19
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13. Certification
The defendant and defendant's counsel certify that this plea agreement
has been read in its entirety by (or has been read to) the defendant and that defendant
fully understands its terms. ~
DATEDthis ~ dayof V~025.
GREGORY W. KEHOE
United States Attorney
SimonR. Eth
Assistant United States Attorney
Roy W. Foxall, Esq.
Attorney for Defendant
~ asA f'· ~
Assistant United States Attorney
Chief, Fort Myers Division
Defendant's Initials£ 20
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