Plea Agreement for Defendant Gabriela Llerenas — United States v. Llerenas (Case 5:21-cr-00187-JWH)

Summary

A plea agreement for Gabriela Llerenas, also known as Maria G. Sandoval, filed September 8, 2021 as Document 6 in United States v. Llerenas, No. 5:21-cr-00187-JWH, in the U.S. District Court for the Central District of California. The agreement with the U.S. Attorney's Office concerns its investigation of fraudulent unemployment insurance claims filed with the California Employment Development Department from about April 2020. Llerenas agrees to plead guilty to a one-count information charging mail fraud under 18 U.S.C. § 1341. She also agrees to forfeit $621,124.00 seized on or about October 20, 2020 as traceable proceeds of the offense. The agreement, prepared by Assistant U.S. Attorney Ranee A. Katzenstein of the Major Frauds Section, includes a statement of facts signed by the defendant and her counsel.

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FILED

Acting United States Attorney
SCOTT M. GARRINGER 9/8/2021
Assistant United States Attorney

CENTRAL DISTRICT OF CALIFORNIA
BY: JB DEPUTY

Chief, Criminal Division
RANEE A. KATZENSTEIN (Cal. Bar No. 187111)
Assistant United States Attorney
Chief, Major Frauds Section
1100 United States Courthouse
312 North Spring Street
Los Angeles, California 90012
Telephone: (213) 894-2432
Facsimile: (213) 894-6269
E-mail: ranee.katzenstein@usdoj.gov

Attorneys for Plaintiff
UNITED STATES OF AMERICA

UNITED STATES DISTRICT COURT
FOR THE CENTRAL DISTRICT OF CALIFORNIA
UNITED STATES OF AMERICA, No. CR 5:21-cr-00187-JWH

Plaintunr, PLEA AGREEMENT FOR DEFENDANT
GABRIELA LLERENAS

GABRIELA LLERENAS,
aka “Maria G. Sandoval,”

Defendant.

1. This constitutes the plea agreement between GABRIELA
LLERENAS, also known as “Maria G. Sandoval,” (“defendant”) and the
United States Attorney’s Office for the Central District of
California (the “USAO”) in the investigation of fraudulent
Unemployment Insurance Claims filed with the California Employment

Development Department (“EDD”) from in or about April 2020 to at

bind any other federal, state, local, or foreign prosecuting,
enforcement, administrative, or regulatory authorities.

least October 2020. This agreement is limited to the USAO and cannot
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DEFENDANT’ S OBRLTIGATTONS

Zz. Defendant agrees to:

a. Give up the right to indictment by a grand jury and,
at the earliest opportunity requested by the USAO and provided by the
Court, apoear and plead guilty to a one-count information in the form
attached to this agreement as Exhibit A or a substantially similar
form, which charges defendant with mail fraud in violation of 18

b. Agree that all court appearances, including her change
of plea hearing and sentencing hearing, may proceed by video-
teleconference (“VTC”) or telephone, if VTC is not reasonably
available, so long as such appearances are authorized by Order of the
Chief Judge 20-043 or another order, rule, or statute. Defendant
understands that, under the United States Constitution, the United
States Code, and the Federal Rules of Criminal Procedure (including
Rules 11, 32, and 43), she may have the right to be physically
present at these hearings. Defendant understands that right and,
after consulting with counsel, voluntarily agrees to waive it and to
proceed remotely. Defense counsel also joins in this consent,
agreement, and waiver. Specifically, this agreement includes, but is
not limited to, the following:

“igs Defendant consents under Federal Rules of
Criminal Procedure 5(f) and 10(c) and Section 15002 (b) of the CARES
Act to proceed with her initial appearance and arraignment by VTC or
telephone, if VTC is not reasonably available.

ii. Defendant consents under Section 15002(b) of the

CARES Act to proceed with her waiver of indictment, under Federal
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Rule of Criminal Procedure 7(b), by VTC or telephone, if VTC is not
reasonably available.

1ii. Defendant consents under Section 15002(b) of the
CARES Act to proceed with her change of plea hearing by VTC or
telephone, if VTC is not reasonably available.

iv. Defendant consents under Section 15002(b) of the
CARES Act to proceed with her sentencing hearing by VTC or telephone,
if VTC is not reasonably available.

ve. Defendant consents under 18 U.S.C. § 3148 and
Section 15002(b) of the CARES Act to proceed with any hearing
regarding alleged violations of the conditions of pretrial release by
VTC or telephone, if VTC is not reasonably available.

Ge Not contest facts agreed to in this agreement.

dl. Abide by all agreements regarding sentencing contained
in this agreement.

e. Appear for all court appearances, surrender as ordered
for service of sentence, obey all conditions of any bond, and obey
any other ongoing court order in this matter.

fo Not commit any crime; however, offenses that would be
excluded for sentencing purposes under United States Sentencing
Guidelines (“U.S.S.G.” or “Sentencing Guidelines”) § 4A1.2(c) are not
within the scope of this agreement.

g. Be truthful at all times with the United States
Probation and Pretrial Services Office and the Court.

h. Pay the applicable special assessment at or before the
time of sentencing unless defendant has demonstrated a lack of

ability to pay such assessments.
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3 Defendant further agrees to cooperate fully with the
Department of Labor-Office of Inspector General and, as directed by
the USAO, any other federal, state, local, or foreign prosecuting,
enforcement, administrative, or regulatory authority. This
cooperation requires defendant to:

a. Respond truthfully and completely to all questions
that may be put to defendant, whether in interviews, before a grand
jury, or at any trial or other court proceeding.

b. Attend all meetings, grand jury sessions, trials or
other proceedings at which defendant’s presence is requested by the
USAO or compelled by subpoena or court order.

G.. Produce voluntarily all documents, records, or other
tangible evidence relating to matters about which the USAO, or its
designee, inquires.

4. For purposes of this agreement: (1) “Cooperation
Information” shall mean any statements made, or documents, records,
tangible evidence, or other information provided, by defendant
pursuant to defendant’s cooperation under this agreement or pursuant
to the letter agreement previously entered into by the parties dated
February 25, 2021 (the “Letter Agreement”); and (2) “Plea
Information” shall mean any statements made by defendant, under oath,
at the guilty plea hearing and the agreed to factual basis statement
in this agreement.

5. Defendant further agrees:

a. To forfeit all right, title, and interest in and to
any and all monies, properties, and/or assets of any kind, derived
from or acquired as a result of the illegal activity to which
defendant is pleading guilty, specifically including, but not limited

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to, the approximately $621,124.00 in U.S. Currency seized on or about
October 20, 2020 (the “Forfeitable Property”), which Forfeitable
Property defendant agrees constitutes traceable proceeds of the 18
U.S.C. § 1341 violation for which defendant is entering a plea of
guilty and renders the Forfeitable Property subject to forfeiture
pursuant to 18 U.S.C. § 981, 18 U.S.C. § 982, 21 U.S.C. § 2461(c), or
otherwise.

b. To the Court’s entry of an order of forfeiture at or
before sentencing with respect to the Forfeitable Property and to the
forfeiture of the Forfeitable Property.

om To take whatever steps are necessary to pass to the
United States clear title to the Forfeitable Property, including,
without limitation, the execution of a consent decree of forfeiture,
the execution of waivers by third parties who might claim an interest
in the Forfeitable Property, and the completing of any other legal
documents required for the transfer of title of the Forfeitable
Property to the United States.

d. Not to contest any administrative forfeiture
proceedings or civil judicial proceedings commenced against the
Forfeitable Property. If defendant submitted a claim and/or petition
for remission for all or part of the Forfeitable Property on behalf
of herself or any other individual or entity, defendant shall and
hereby does withdraw any such claims or petitions, and further agrees
to waive any right she may have to seek remission or mitigation of
the forfeiture of the Forfeitable Property. Defendant further waives
any and all notice requirements of 18 U.S.C. § 983(a) (1) (A).

e. Not to assist any other individual in any effort
falsely to contest the forfeiture of the Forfeitable Property.

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f. Not to claim that reasonable cause to seize the
Forfeitable Property was lacking.

gq. To prevent the transfer, sale, destruction, or loss of
any and all assets described above to the extent defendant has the
ability to do so.

h. To fill out and deliver to the USAO a completed
financial statement listing defendant’s assets on a form provided by
the USAO.

1. That forfeiture of Forfeitable Property shall not be
counted toward satisfaction of any special assessment, fine,
restitution, costs, or other penalty the Court may impose.

Whe With respect to any criminal forfeiture ordered as a
result of this plea agreement, defendant waives: (1) the requirements
of Federal Rules of Criminal Procedure 32.2 and 43(a) regarding
notice of the forfeiture in the charging instrument, announcements of
the forfeiture at sentencing, and incorporation of the forfeiture in
the judgment; (2) all constitutional and statutory challenges to the
forfeiture (including by direct appeal, habeas corpus or any other
means); and (3) all constitutional, legal, and equitable defenses to
the forfeiture of the Forfeitable Property in any proceeding on any
grounds including, without limitation, that the forfeiture
constitutes an excessive fine or punishment. Defendant acknowledges
that the forfeiture of the Forfeitable Property is part of the
sentence that may be imposed in this case and waives any failure by
the Court to advise defendant of this, pursuant to Federal Rule of
Criminal Procedure 11(b) (1) (J), at the time the Court accepts

defendant’s guilty plea.
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THE USAO’S OBLIGATIONS

Gs The USAO agrees to:
a. Not contest facts agreed to in this agreement.
is Abide by all agreements regarding sentencing contained

in this agreement.

ol At the time of sentencing, provided that defendant
demonstrates an acceptance of responsibility for the offense up to
and including the time of sentencing, recommend a two-level reduction
in the applicable Sentencing Guidelines offense level, pursuant to
U.S.S.G. § 3E1.1, and recommend and, if necessary, move for an
additional one-level reduction if available under that section.

d. Recommend that defendant be sentenced to a term of
imprisonment no higher than the low end of the applicable Sentencing
Guidelines range, provided that the offense level used by the Court
to determine that range is 24 or higher and provided that the Court
does not depart downward in offense level or criminal history
category. For purposes of this agreement, the low end of the
Sentencing Guidelines range is that defined by the Sentencing Table
in JU.S.S.G. Chapter 5, Part A.

e. Except for criminal tax violations (including
conspiracy to commit such violations chargeable under 18 U.S.C.

§ 371), not further criminally prosecute defendant for violations of
18 U.S.C. §§ 1028A (Aggravated Identity Theft), 1029 (Fraud and
related activity in connection with access devices), 1341 (Mail
Fraud), 1343 (Wire Fraud), and 1349 (Attempt and Conspiracy to Commit
Mail and/or Wire Fraud) arising out of defendant’s conduct described
in the agreed-to factual basis set forth in Exhibit B attached
hereto. Defendant understands that the USAO is free to criminally

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prosecute defendant for any other unlawful past conduct or any
unlawful conduct that occurs after the date of this agreement.
Defendant agrees that at the time of sentencing the Court may
consider the uncharged conduct in determining the applicable
Sentencing Guidelines range, the propriety and extent of any
departure from that range, and the sentence to be imposed after
consideration of the Sentencing Guidelines and all other relevant
factors under 18 U.S.C. § 355342).

ins The USAO further agrees:

ag Not to offer as evidence in its case-in-chief in the
above-captioned case or any other criminal prosecution that may be
brought against defendant by the USAO, or in connection with any
sentencing proceeding in any criminal case that may be brought
against defendant by the USAO, any Cooperation Information.

Defendant agrees, however, that the USAO may use both Cooperation
Information and Plea Information: (1) to obtain and pursue leads to
other evidence, which evidence may be used for any purpose, including
any criminal prosecution of defendant; (2) to cross-examine defendant
should defendant testify, or to rebut any evidence offered, or
argument or representation made, by defendant, defendant’s counsel,
or a witness called by defendant in any trial, sentencing hearing, or
other court proceeding; and (3) in any criminal prosecution of
defendant for false statement, obstruction of justice, or perjury.

b. Not to use Cooperation Information against defendant
at sentencing for the purpose of determining the applicable guideline
range, including the appropriateness of an upward departure, or the
sentence to be imposed, and to recommend to the Court that
Cooperation Information not be used in determining the applicable

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guideline range or the sentence to be imposed. Defendant
understands, however, that Cooperation Information will be disclosed
to the United States Probation and Pretrial Services Office and the
Court, and that the Court may use Cooperation Information for the
purposes set forth in U.S.S.G § 1B1.8(b) and for determining the
sentence to be imposed.

e. In connection with defendant’s sentencing, to bring to
the Court’s attention the nature and extent of defendant’s
cooperation.

d. If the USAO determines, in its exclusive judgment,
that defendant has both complied with defendant’s obligations under
paragraphs 2 and 3 above and provided substantial assistance to law
enforcement in the prosecution or investigation of another
(“substantial assistance”), to move the Court pursuant to U.S.S.G.

§ 5K1.1 to fix an offense level and corresponding guideline range
below that otherwise dictated by the sentencing guidelines, and to
recommend a term of imprisonment within this reduced range.

DEFENDANT’ S_ UNDERSTANDINGS REGARDING COOPERATION

8. Defendant understands the following:

a. Any knowingly false or misleading statement by
defendant will subject defendant to prosecution for false statement,
obstruction of justice, and perjury and will constitute a breach by
defendant of this agreement.

b. Nothing in this agreement requires the USAO or any
other prosecuting, enforcement, administrative, or regulatory
authority to accept any cooperation or assistance that defendant may

offer, or to use it in any particular way.
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Cc. Defendant cannot withdraw defendant’s guilty plea if
the USAO does not make a motion pursuant to U.S.S.G. § 5K1l.1 for a
reduced guideline range or if the USAO makes such a motion and the
Court does not grant it or if the Court grants such a USAO motion but
elects to sentence above the reduced range.

d. At this time the USAO makes no agreement or
representation as to whether any cooperation that defendant has
provided or intends to provide constitutes or will constitute
substantial assistance. The decision whether defendant has provided
substantial assistance will rest solely within the exclusive judgment
of the USAO.

e. The USAO’s determination whether defendant has
provided substantial assistance will not depend in any way on whether
the government prevails at any trial or court hearing in which
defendant testifies or in which the government otherwise presents
information resulting from defendant’s cooperation.

NATURE OF THE OFFENSE

9. Defendant understands that for defendant to be guilty of
the crime charged in count one of the information, that is, mail
fraud, in violation of Title 18, United States Code, Sections 1341,
the following must be true:

a. First, the defendant knowingly participated in a
scheme or plan to defraud, or a scheme or plan for obtaining money or
property by means of false or fraudulent pretenses, representations,
or promises;

b. Second, the statements made or facts omitted as part

of the scheme were material, that is, they had a natural tendency to

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influence, or were capable of influencing, a person to part with
money or property;

Cc. Third, the defendant acted with the intent to defraud,
that is, the intent to deceive and cheat; and

d. Fourth, the defendant used, or caused to be used, the
mails to carry out or attempt to carry out an essential part of the
scheme. A mailing is caused when one knows that the mails will be
used in the ordinary course of business or when one can reasonably
foresee such use. It does not matter whether the material mailed was
itself false or deceptive so long as the mail was used as a part of
the scheme, nor does it matter whether the scheme or plan was
successful or that any money or property was obtained.

PENALTIES AND RESTITUTION

10. Defendant understands that the statutory maximum sentence
that the Court can impose for a violation of Title 18, United States
Code, Section 1341, is: a 20-year term of imprisonment; a 3-year
period of supervised release; a fine of $250,000 or twice the gross
gain or gross loss resulting from the offense, whichever is greatest;
and a mandatory special assessment of $100.

11. Defendant understands that defendant will be required to
pay full restitution to the victim(s) of the offense to which
defendant is pleading guilty. Defendant agrees that, in return for
the USAO’s compliance with its obligations under this agreement, the
Court may order restitution to persons other than the victim(s) of
the offense to which defendant is pleading guilty and in amounts
greater than those alleged in the count to which defendant is
pleading guilty. In particular, defendant agrees that the Court may
order restitution to any victim of any of the following for any

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losses suffered by that victim as a result: (a) any relevant conduct,
as defined in U.S.S.G. § 1Bl1.3, in connection with the offense to
which defendant is pleading guilty; and (b) any charges not
prosecuted pursuant to this agreement as well as all relevant
conduct, as defined in U.S.S.G. § 1B1.3, in connection with those
charges. The parties currently believe that the applicable amount of
restitution is at least $1,633,487 and the government currently
believes that the applicable amount of restitution is approximately
$4,298,093, but the parties both recognize and agree that these
amounts could change based on facts that come to the attention of the
parties prior to sentencing.

12. Defendant agrees that any and all fines and/or restitution
ordered by the Court will be due immediately. The government is not
precluded from pursuing, in excess of any payment schedule set by the
Court, any and all available remedies by which to satisfy defendant’s
payment of the full financial obligation, including referral to the
Treasury Offset Program. To that end, the government will file a
post-judgment lien against defendant’s property, but agrees to
refrain from any active collection action against defendant’s primary
residence. Notwithstanding the foregoing, in the event defendant
sells, conveys, or otherwise transfers her interest in her primary
residence, defendant agrees and consents that the government will be
entitled to apply the proceeds of such transfer to her anticipated
restitution obligation.

13. Defendant understands that supervised release is a period
of time following imprisonment during which defendant will be subject
to various restrictions and requirements. Defendant understands that
if defendant violates one or more of the conditions of any supervised

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release imposed, defendant may be returned to prison for all or part
of the term of supervised release authorized by statute for the
offense that resulted in the term of supervised release, which could
result in defendant serving a total term of imprisonment greater than
the statutory maximum stated above.

14. Defendant understands that, by pleading guilty, defendant
may be giving up valuable government benefits and valuable civic
rights, such as the right to vote, the right to possess a firearm,
the right to hold office, and the right to serve on a jury.

Defendant understands that she is pleading guilty to a felony and
that it is a federal crime for a convicted felon to possess a firearm
or ammunition. Defendant understands that the conviction in this
case may also subject defendant to various other collateral
consequences, including but not limited to revocation of probation,
parole, or supervised release in another case and suspension or
revocation of a professional license. Defendant understands that
unanticipated collateral consequences will not serve as grounds to
withdraw cefendant’s guilty plea.

15. Defendant and her counsel have discussed the fact that, and
defendant understands that, if defendant is not a United States
Citizen, the conviction in this case makes it practically inevitable
and a virtual certainty that defendant will be removed or deported
from the United States. Defendant may also be denied United States
citizenship and admission to the United States in the future.
Defendant understands that while there may be arguments that
defendant can raise in immigration proceedings to avoid or delay
removal, removal is presumptively mandatory and a virtual certainty
in this case. Defendant further understands that removal and

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immigration consequences are the subject of a separate proceeding and
that no one, including her attorney or the Court, can predict to an
absolute certainty the effect of her conviction on her immigration
status. Defendant nevertheless affirms that she wants to plead
guilty regardless of any immigration consequences that her plea may
entail, even if the consequence is automatic removal from the United

FACTUAL BASIS

16. Defendant admits that defendant is, in fact, guilty of the
offense to which defendant is agreeing to plead guilty. Defendant
and the USAO agree to the statement of facts provided in Exhibit B
attached hereto and agree that this statement of facts is sufficient
to support a plea of guilty to the charge described in this agreement
and to establish the Sentencing Guidelines factors set forth in
paragraph 18 below but is not meant to be a complete recitation of
all facts relevant to the underlying criminal conduct or all facts
known to either party that relate to that conduct.

SENTENCING FACTORS

17. Defendant understands that in determining defendant’s
sentence the Court is required to calculate the applicable Sentencing
Guidelines range and to consider that range, possible departures
under the Sentencing Guidelines, and the other sentencing factors set
forth in 18 U.S.C. § 3553(a). Defendant understands that the
Sentencing Guidelines are advisory only, that defendant cannot have
any expectation of receiving a sentence within the calculated
Sentencing Guidelines range, and that after considering the
Sentencing Guidelines and the other § 3553(a) factors, the Court will
be free to exercise its discretion to impose any sentence it finds

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appropriate up to the maximum set by statute for the crime of
conviction.
18. Defendant and the USAO agree to the following applicable

Sentencing Guidelines factors:

Base Offense Level: 7 U.S.S.G. § 2Bl.1(a) (1)
Specific Offense +16
Characteristics

Loss greater than $1,500,000
but less than $9,500,000 +18 (J)

More than 10 Victims #2 VMes.Sait. S 2B. (by 02) (A) ay

Unauthorized use of means of
ID to obtain other means of
ID and/or possession of
means of ID that were
unlawfully produced by use

of another means of ID +2 UisSw5 1G... GQ 2B1 . Go) (Eb) ()
Acceptance of Responsibility -3 U.S f.G. & BEL. (fay, (bs)
TOTAL OFFENSE LEVEL 24

or

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The USAO will agree to a two-level downward adjustment for acceptance
of responsibility (and, if applicable, move for an additional one-
level downward adjustment under U.S.S.G. § 3E1.1(b)) only if the
conditions set forth in paragraph 3(c) are met and if defendant has
not committed, and refrains from committing, acts constituting
obstruction of justice within the meaning of U.S.S.G. § 3Cl.1, as
discussed below. Regarding loss, the parties agree that the loss
caused by defendant’s offense, taking into account relevant conduct,
is at least $1,633,487; the government reserves the right to argue
that the loss is $4,298,093 and defendant reserves the right to argue

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that the loss does not exceed $3.5 million. Subject to paragraphs
7(d) above and 31 below, defendant and the USAO agree not to seek,
argue, or suggest in any way, either orally or in writing, that any
other specific offense characteristics, adjustments, or departures
relating to the offense level be imposed. Defendant agrees, however,
that if, after signing this agreement but prior to sentencing,
defendant were to commit an act, or the USAO were to discover a
previously undiscovered act committed by defendant prior to signing
this agreement, which act, in the judgment of the USAO, constituted
obstruction of justice within the meaning of U.S.S.G. § 3C1.1, the
USAO would be free to seek the enhancement set forth in that section
and to argue that defendant is not entitled to a downward adjustment
for acceptance of responsibility under U.S.S.G. § 3E1.1.

19. Defendant understands that there is no agreement as to
defendant’s criminal history or criminal history category.

20. Defendant and the USAO reserve the right to argue for a
sentence outside the sentencing range established by the Sentencing
Guidelines based on the factors set forth in 18 U.S.C. § 3553(a)(1),
(a) (2), (a) (3), (a) (6), and (a) (7).

WAIVER OF CONSTITUTIONAL RIGHTS

21. Defendant understands that by pleading guilty, defendant

gives up the following rights:

a. The right to persist ina plea of not guilty.

Px. The right to a speedy and public trial by jury.

a. The right to be represented by counsel -- and if
necessary have the Court appoint counsel -- at trial. Defendant

understands, however, that, defendant retains the right to be

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represented by counsel -- and if necessary have the Court appoint
counsel -- at every other stage of the proceeding.
feline The right to be presumed innocent and to have the

burden of proof placed on the government to prove defendant guilty
beyond a reasonable doubt.

a The right to confront and cross-examine witnesses
against defendant.

f. The right to testify and to present evidence in
opposition to the charges, including the right to compel the
attendance of witnesses to testify.

g. The right not to be compelled to testify, and, if
defendant chose not to testify or present evidence, to have that
choice not be used against defendant.

h. Any and all rights to pursue any affirmative defenses,
Fourth Amendment or Fifth Amendment claims, and other pretrial
motions that have been filed or could be filed.

WAIVER OF APPEAL OF CONVICTION

22. Defendant understands that, with the exception of an appeal
based on a claim that defendant’s guilty plea was involuntary, by
pleading guilty defendant is waiving and giving up any right to
appeal defendant’s conviction on the offense to which defendant is
pleading guilty. Defendant understands that this waiver includes,
but is not limited to, arguments that the statute to which defendant
is pleading guilty is unconstitutional, and any and all claims that
the statement of facts provided herein is insufficient to support

defendant’s plea of guilty.

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ase 5:21-cr-00187-JWH Document6 Filed 09/08/21 Page 18 of 39 Page ID #:32

LIMITED MUTUAL WAIVER OF APPEAL OF SENTENCE

23. Defendant agrees that, provided the Court imposes a total
term of imprisonment on the count of conviction within or below the
range corresponding to an offense level of 26 and the criminal
history category calculated by the Court, defendant gives up the
right to appeal all of the following: (a) the procedures and
calculations used to determine and impose any portion of the
sentence; (b) the term of imprisonment imposed by the Court; (c) the
fine imposed by the Court, provided it is within the statutory
maximum; (d) to the extent permitted by law, the constitutionality or
legality of defendant’s sentence, provided it is within the statutory
maximum; (e) the amount and terms of any restitution order, provided
it requires payment of no more than $4,298,093; (f) the term of
probation or supervised release imposed by the Court, provided it is
within the statutory maximum; and (g) any of the following conditions
of probation or supervised release imposed by the Court: the
conditions set forth in General Order 20-04 of this Court; the drug
testing conditions mandated by 18 U.S.C. §$§ 3563(a) (5) and 3583(d);
and the alcohol and drug use conditions authorized by 18 U.S.C.

§ 3563 (b) (7).

24. The USAO agrees that, provided (a) all portions of the
sentence are at or below the statutory maximum specified above and
(b) the Court imposes a term of imprisonment within or above the
range corresponding to an offense level of 24 and the criminal
history category calculated by the Court, the USAO gives up its right
to appeal any portion of the sentence, with the exception that the
USAO reserves the right to appeal the amount of restitution ordered
if that amount is less than $4,298,093.

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Ase 5:21-cr-00187-JWH Document6 Filed 09/08/21 Page 19 of 39 Page ID #:33

RESULT OF WITHDRAWAL OF GUILTY PLEA

25. Defendant agrees that if, after entering a guilty plea
pursuant to this agreement, defendant seeks to withdraw and succeeds
in withdrawing defendant’s guilty plea on any basis other than a
claim and finding that entry into this plea agreement was
involuntary, then (a) the USAO will be relieved of all of its
obligations under this agreement; and (b) should the USAO choose to
pursue any charge that was not filed as a result of this agreement,
then (i) any applicable statute of limitations will be tolled between
the date of defendant’s signing of this agreement and the filing
commencing any such action; and (ii) defendant waives and gives up
all defenses based on the statute of limitations, any claim of pre-
indictment delay, or any speedy trial claim with respect to any such
action, except to the extent that such defenses existed as of the
date of defendant’s signing this agreement.

RESULT OF VACATUR, REVERSAL OR SET-ASIDE

26. Defendant agrees that if the count of conviction is
vacated, reversed, or set aside, both the USAO and defendant will be
released from all their obligations under this agreement.

EFFECTIVE DATE OF AGREEMENT

27. This agreement is effective upon signature and execution of
all required certifications by defendant, defendant’s counsel, and an
Assistant United States Attorney.

BREACH OF AGREEMENT

28. Defendant agrees that if defendant, at any time after the
effective date of this agreement, knowingly violates or fails to
perform any of defendant’s obligations under this agreement (“a
breach”), the USAO may declare this agreement breached. All of

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ase 5:21-cr-00187-JWH Document 6 Filed 09/08/21 Page 20 of 39 Page ID #:34

defendant’s obligations are material, a single breach of this
agreement is sufficient for the USAO to declare a breach, and
defendant shall not be deemed to have cured a breach without the
express agreement of the USAO in writing. If the USAO declares this
agreement breached, and the Court finds such a breach to have
occurred, then: (a) if defendant has previously entered a guilty plea
pursuant to this agreement, defendant will not be able to withdraw
the guilty plea, and (b) the USAO will be relieved of all its
obligations under this agreement.

29. Following the Court’s finding of a knowing breach of this
agreement by defendant, should the USAO choose to pursue any charge
that was either dismissed or not filed as a result of this agreement,
then:

a. Defendant agrees that any applicable statute of
limitations is tolled between the date of defendant’s signing of this
agreement and the filing commencing any such action.

lore Defendant waives and gives up all defenses based on
the statute of limitations, any claim of pre-indictment delay, or any
speedy trial claim with respect to any such action, except to the
extent that such defenses existed as of the date of defendant’s
Signing this agreement.

6G. Defendant agrees that: (1) any statements made by
defendant, under oath, at the guilty plea hearing (if such a hearing
occurred prior to the breach); (ii) the agreed to factual basis
statement in this agreement; and (iii) any evidence derived from such
statements, shall be admissible against defendant in any such action
against defendant, and defendant waives and gives up any claim under
the United States Constitution, any statute, Rule 410 of the Federal

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Rules of Evidence, Rule 11(f) of the Federal Rules of Criminal
Procedure, or any other federal rule, that the statements or any
evidence derived from the statements should be suppressed or are
inadmissible.

COURT AND UNITED STATES PROBATION AND PRETRIAL SERVICES

OFFICE NOT PARTIES

30. Defendant understands that the Court and the United States
Probation and Pretrial Services Office are not parties to this
agreement and need not accept any of the USAO’s sentencing
recommendations or the parties’ agreements to facts or sentencing

31. Defendant understands that both defendant and the USAO are
free to: (a) Supplement the facts by supplying relevant information
to the United States Probation and Pretrial Services Office and the
Court, (b) correct any and all factual misstatements relating to the
Court’s Sentencing Guidelines calculations and determination of
sentence, and (c) argue on appeal and collateral review that the
Court’s Sentencing Guidelines calculations and the sentence it
chooses to impose are not error, although each party agrees to
maintain its view that the calculations in paragraph 14 are
consistent with the facts of this case. While this paragraph permits
both the USAO and defendant to submit full and complete factual
information to the United States Probation and Pretrial Services
Office and the Court, even if that factual information may be viewed
as inconsistent with the facts agreed to in this agreement, this
paragraph does not affect defendant’s and the USAO’s obligations not

to contest the facts agreed to in this agreement.

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ase 5:21-cr-00187-JWH Document6 Filed 09/08/21 Page 22 of 39 Page ID #:36

32. Defendant understands that even if the Court ignores any
sentencing recommendation, finds facts or reaches conclusions
different from those agreed to, and/or imposes any sentence up to the
maximum established by statute, defendant cannot, for that reason,

withdraw defendant’s guilty plea, and defendant will remain bound to

fulfill all defendant’s obligations under this agreement. Defendant
understands that no one —-- not the prosecutor, defendant’s attorney,
or the Court -- can make a binding prediction or promise regarding

the sentence defendant will receive, except that it will be within
the statutory maximum.

NO ADDITIONAL AGREEMENTS

33. Defendant understands that, except as set forth herein,
there are no promises, understandings, or agreements between the USAO
and defendant or defendant’s attorney, and that no additional
promise, understanding, or agreement may be entered into unless in a
writing signed by all parties or on the record in court.

///
///
///

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ase 5:21-cr-00187-JWH Document6 Filed 09/08/21 Page 23 of 39 Page ID #:37

PLEA AGREEMENT PART OF THE GUILTY PLEA HEARING

AGREED AND ACCEPTED

UNITED STATES ATTORNEY’S OFFICE
FOR THE CENTRAL DISTRICT OF
CALIFORNIA

TRACY L. WILKISON
Acting United States Attorney

/ ¢

f ——

34. The parties agree that this agreement will be considered
part of the record of defendant’s guilty plea hearing as if the

entire agreement had been read into the record of the proceeding.

9/8/2021

RANEE A. KATZENSTEIN

“he nt United “Wh Attorney

GABRIELA LLERENAS

MA, C—

RONALD L. FREEMAN, ESQ.
Attorney for Defendant Gabriela
Llerenas

///
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Date

Date

Date
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Gase 5:21-cr-00187-JWH Document6 Filed 09/08/21 Page 24 of 39 Page ID #:38

CERTIFICATION OF DEFENDANT

I have read this agreement in its entirety. I have had enough
time to review and consider this agreement, and I have carefully and
thoroughly discussed every part of it with my attorney. I understand
the terms of this agreement, and I voluntarily agree to those terms.
I have discussed the evidence with my attorney, and my attorney has
advised me of my rights, of possible pretrial motions that might be
filed, of possible defenses that might be asserted either prior to or
at trial, of the sentencing factors set forth in 18 U.S.C. § 3553(a),
of relevant Sentencing Guidelines provisions, and of the consequences
of entering into this agreement. No promises, inducements, or
representations of any kind have been made to me other than those
contained in this agreement. No one has threatened or forced me in
any way to enter into this agreement. I am satisfied with the
representation of my attorney in this matter, and I am pleading
guilty because I am guilty of the charge and wish to take advantage

of the promises set forth in this agreement, and not for any other

GABRIELA LLERENAS Date
Defendant

///
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a 5:21-cr-00187-JWH Document 6 Filed 09/08/21 Page 25 of 39 Page ID #:39

CERTIFICATION OF DEFENDANT’ S ATTORNEY

I am GABRIELA LLERENAS’s attorney. I have carefully and
thoroughly discussed every part of this agreement with my client.
Further, I have fully advised my client of her rights, of possible
pretrial motions that might be filed, of possible defenses that might
be asserted either prior to or at trial, of the sentencing factors
set forth in 18 U.S.C. § 3553(a), of relevant Sentencing Guidelines
provisions, and of the consequences of entering into this agreement.
To my knowledge: no promises, inducements, or representations of any
kind have been made to my client other than those contained in this
agreement; no one has threatened or forced my client in any way to
enter into this agreement; my client’s decision to enter into this
agreement is an informed and voluntary one; and the factual basis set
forth in this agreement is sufficient to support my client’s entry of

a guilty plea pursuant to this agreement.

RONALD L. FREEMAN, ESQ&— Date
Attorney for Defendant GABRIELLA
LLERENAS

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EXHIBIT A

UNITED STATES DISTRICT COURT

FOR THE CENTRAL DISTRICT OF CALIFORNIA

UNITED STATES OF AMERICA, No. CR
Plaintiff, INFORMATION
Vv. [18 U.S.C. § 1341: Mail Fraud]

aka “Maria G. Sandoval,”

Defendant.

The Acting United States Attorney charges:

[18 U.S.C. S§$ 1341, 2(b)]

A. INTRODUCTORY ALLEGATIONS

At times relevant to this Information:

1. Defendant GABRIELA LLERENAS, also known as “Maria G.

7

Sandoval,” was a resident of Perris, California.

2. California’s Employment Development Department (“EDD”) was
the administrator of the unemployment insurance (“UI”) benefit
program for the State of California.

3. On March 13, 2020, the President of the United States

declared COVID-19 an emergency under the Robert T. Stafford Disaster
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Relief and Emergency Assistance Act. As a result, Congress passed
the Coronavirus Aid, Relief, and Economic Security Act (“CARES Act”),
which the President signed into law on March 27, 2020. The CARES Act
provided over $2 trillion in economic relief protections to the
American people from the public health and economic impacts of COVID-
19.

4. Prior to the enactment of the CARES Act, to be eligible for
UI administered by EDD, a person had to have been employed and worked
in California and received at least a certain amount of wages from an
employer in the 18 months preceding his/her UI benefits claim.
Because of this requirement, self-employed workers, independent
contractors, and employees with insufficient earnings were not
eligible to receive regular UI benefits.

5. The CARES Act established a new program -- Pandemic
Unemployment Assistance (“PUA”) -- to provide unemployment benefits
during the COVID-19 pandemic to people who did not qualify for
regular unemployment insurance benefits, including business owners,
self-employed workers, independent contractors, and those with a
limited work history who were out of business or had significantly
reduced their services as a direct result of the pandemic. UI
benefits provided under the PUA program are sometimes referred to as
PUA benefits.

6. Under the PUA provisions of the CARES Act, a person who was
a business owner, self-employed worker, independent contractor, or
gig worker could qualify for PUA benefits administered by EDD if
he/she previously performed such work in California and was
unemployed, partially unemployed, unable to work, or unavailable to

work due to a COVID-19-related reason.
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7. Persons applying for PUA benefits did not need to submit
any supporting documents to EDD with their applications. Claimants
entered their total income for the 2019 calendar year on the
application. The stated income was used to pay the minimum benefits
of $167 per week. EDD could request documentation to provide proof
of the stated income.

8. A PUA claimant was required to answer various questions to
establish his/her eligibility for PUA benefits. The claimant was
required to provide his/her name, Social Security Number, and mailing
address. The claimant was also required to identify a qualifying
occupational status and COVID-19 related reason for being out of
work.

9. After it accepted a UI claim, including a claim submitted
pursuant to the PUA program, EDD typically deposited UI funds every
two weeks to an Electronic Bill Payment (“EBP”) debit card
administered by Bank of America (“BofA”), which the claimant could
use to pay for his/her expenses. The EBP card was mailed via the
United States Postal Service to the claimant at the address the
claimant provided in his/her UI application.

B. THE SCHEME TO DEFRAUD

10. Beginning by at least April 2020 and continuing through at
least October 2020, in Riverside and Los Angeles Counties, within the
Central District of California, and elsewhere, defendant LLERENAS,
together with others known and unknown to the Acting United States
Attorney, knowingly and with the intent to defraud, devised,
participated in, and executed a scheme to defraud EDD and the United
States Treasury as to material matters, and to obtain money and

property from EDD and the United States Treasury, namely, UI
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benefits, including PUA benefits, by means of material false and
fraudulent pretenses, representations, and promises, and the
concealment of material facts.

11. The fraudulent scheme operated, in substance, as follows:

a. Defendant LLERENAS filed and caused the filing with
EDD of fraudulent applications for UI benefits that falsely asserted
the named claimants were self-employed independent contractors who
had been negatively affected by the COVID-19 pandemic, thereby
triggering eligibility for UI benefits under the PUA provision of the
CARES Act. Defendant LLERENAS obtained some of the names, Social
Security Numbers and other identifying information she used to submit
the fraudulent claims through her prior work as a tax preparer.

b. In some instances, defendant LLERENAS falsely asserted
and caused to be asserted on the UI applications submitted in
furtherance of the scheme that the claimants were residents of
California entitled to UI benefits administered by EDD when, in fact,
they were not and defendant knew they were not.

on In some instances, defendant LLERENAS falsely asserted
and caused to be asserted inflated income for the named claimants on
their applications in order to receive the maximum benefit amount.

d. In some instances, defendant LLERENAS made up and
caused to be made up the occupation that was listed for the named
claimant on the application.

e. To the contrary, and as defendant LLERENAS then well
knew, many of the persons named as claimants on the applications
defendant LLERENAS filed and caused to be filed had no residential
history in the State of California and/or had not been employed in

the occupations defendant LLERENAS reported and caused to be reported
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on the UI benefits applications she submitted and caused to be
submitted in the names of the named claimants.

f. By falsely asserting that the claimants had worked in
the State of California as independent contractors who had lost work
because of COVID-19, defendant LLERENAS falsely represented and
caused to be falsely represented that the named claimants were
entitled to UI benefits administered by EDD when, as defendant
LLERENAS then knew, they were not.

g. As a result of the fraudulent UI benefit claims that
defendant LLERENAS filed and caused to be filed, EDD authorized BofA
to 1ssue EBP cards in the names of the named claimants. Defendant
LLERENAS knew that the applications she submitted would cause BofA to
mail the EBP debit cards issued to the named claimants to the
addresses defendant LLERENAS provided and caused to be provided on
the fraudulent claim applications, including in some instances
addresses that defendant LLERENAS and/or her associates controlled.

12. Through this scheme, defendant LLERENAS caused
approximately 197 fraudulent PUA claims to be filed with EDD
resulting in losses to EDD and the United States Treasury of at least
$1,633,487.

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B. USE OF THE MAILS

13. On or about August 6, 2020, within the Central District of
California, and elsewhere, defendant LLERENAS, for the purpose of
executing the above-described scheme to defraud, willfully caused an
envelope containing a BofA debit card issued in Jo. G. to be to be
sent and delivered by the United States Postal Service, according to

the directions thereon, to an address in Compton, California.

TRACY L. WILKISON
Acting United States Attorney

SCOTT M. GARRINGER
Assistant United States Attorney
Chief, Criminal Division

RANEE A. KATZENSTEIN
Assistant United States Attorney
Chief, Major Frauds Section
Case 5:21-cr-00187-JWH Document6 Filed 09/08/21 Page 32 of 39 Page ID #:46

EXHIBIT B

STATEMENT OF FACTS

IN SUPPORT OF PLEA AGREEMENT

Defendant GABRIELA LLERENAS, also known as Maria G.
Sandoval,” (“defendant”) represents and admits that the
following facts are true:

Background

At all times relevant to the charge in the Information:

a. Defendant was a resident of Perris, California.

om California’s Employment Development Department (“EDD”)
was the administrator of the unemployment insurance (“UI”)
benefit program for the State of California.

Sy On March 13, 2020, the President of the United States
declared COVID-19 an emergency under the Robert T. Stafford
Disaster Relief and Emergency Assistance Act. As a result,
Congress passed the Coronavirus Aid, Relief, and Economic
Security Act (“CARES Act”), which the President signed into law
on March 27, 2020. The CARES Act provided over $2 trillion in
economic relief protections to the American people from the
public health and economic impacts of COVID-19.

dad. Prior to the enactment of the CARES Act, to be eligible
for UI administered by EDD, a person had to have been employed
and worked in California and received at least a certain amount
of wages from an employer in the 18 months preceding his/her UI
benefits claim. Because of this requirement, self-employed

workers, independent contractors, and employees with

Read and Agreed to ff id
Case 5:21-cr-00187-JWH Document6 Filed 09/08/21 Page 33 of 39 Page ID #:47

insufficient earnings were not eligible to receive regular UI

benefits.
e. The CARES Act established a new program -- Pandemic
Unemployment Assistance (“PUA”) -- to provide unemployment

benefits during the COVID-19 pandemic to people who did not
qualify for regular unemployment insurance benefits including
business owners, self-employed workers, independent contractors,
and those with a limited work history who were out of business
or had significantly reduced their services as a direct result
of the pandemic. UI benefits provided under the PUA program are
sometimes referred to as PUA benefits.

2s Under the PUA provisions of the CARES Act, a person
who was a business owner, self-employed worker, independent
contractor, or gig worker could qualify for PUA benefits
administered by EDD if he/she had previously performed such work
in California and was unemployed, partially unemployed, unable
to work, or unavailable to work due to a COVID-19-related
reason.

g. Persons applying for PUA benefits did not need to
submit any supporting documents to the EDD with their
applications. Claimants entered their total income for the 2019
calendar year on the application. The stated income was used to
pay the minimum benefits of $167 per week. EDD could request
documentation to provide proof of the stated income.

hs A PUA claimant was required to answer various
questions to establish his/her eligibility for PUA benefits.

The claimant was required to provide his/her name, Social

Read and Agreed to
Case 5:21-cr-00187-JWH Document6 Filed 09/08/21 Page 34 of 39 Page ID #:48

Security Number, and mailing address. The claimant was also
required to identify a qualifying occupational status and COVID-
19 related reason for being out of work.

Ls After it accepted a UI claim, including a claim
submitted pursuant to the PUA program, EDD typically deposited
UI funds every two weeks to an Electronic Bill Payment (“EBP”)
debit card administered by the Bank of America (“BofA”), which
the claimant could use to pay for his/her expenses. The EBP
card was mailed via the U.S. Postal Service to the claimant at
the address the claimant provided in his/her UI application.

The Scheme to Defraud

From at least April 2020 through at least October 2020,
defendant, knowingly and with the intent to defraud, devised,
participated in, and executed a scheme to fraudulently obtain UI
benefits, including PUA benefits from EDD and the United States
Treasury as to material matters, and to obtain money and
property from EDD and the United States Treasury, namely, UI
benefits, including PUA benefits, by means of material false and
fraudulent pretenses, representations, and promises, and the
concealment of material facts.

Defendant filed and caused the filing with EDD of
fraudulent applications for UI benefits, which falsely asserted
the named claimants were self-employed independent contractors
who were negatively affected by the COVID-19 pandemic,
triggering eligibility for UI benefits under the PUA provision
of the CARES Act. Defendant obtained some of the names, social

security numbers and other identifying information she used to

Read and Agreed to
Case 5:21-cr-00187-JWH Document6 Filed 09/08/21 Page 35 of 39 Page ID #:49

submit the fraudulent claims through her prior work as a tax
preparer.

In some instances, defendant falsely asserted on the UI
applications submitted in furtherance of the scheme that the
claimants were residents of California entitled to UI benefits
administered by EDD when, in fact, they were not and defendant
knew they were not. In some instances, defendant falsely
reported inflated income to EDD for the named claimants on their
applications in order to receive the maximum benefit amount. In
some instances, defendant made up the occupation that she
reported for the named claimant. Defendant also defrauded and
attempted to defraud at least one of the named claimants by
falsely representing that she was employed by EDD and could
control the distribution of UI benefits, and then demanding
payment from the named claimant in return for filing the UI
application and “releasing” the benefits.

Defendant submitted multiple claims per day. For instance,
on May 11, 14, 18, and 23, 2020, she submitted 12 claims, 8
claims, 13 claims, and 20 claims, respectively. Approximately
133 of the 197 applications that defendant submitted or caused
to be submitted did not include a driver’s license number or
other identifying number for the named claimant. Twenty-five
applications identified the named claimant’s occupation as
baker, baker/decorator, baker/decorator/party planner, cake
decorator, cake decorator/server, decorator, decorator/baker,
event attendant, event attendant/decorator, event

decorator/dessert baker, or event decorator/dessert baker/host;

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Case 5:21-cr-00187-JWH Document6 Filed 09/08/21 Page 36 of 39 Page ID #:50

17 applications identified the named claimant’s occupation as
banquet server or banquet server and host; and nine listed no
occupation at all.

As a result of the fraudulent UI benefits applications that
defendant filed and caused to be filed, the EDD authorized BofA
to issue EBP debit cards in the names of the named claimants.
Defendant knew that the applications she submitted would cause
BofA to mail the EBP debit cards issued to the named claimants
to the addresses defendant provided and caused to be provided on
the fraudulent claim applications, including in some instances
addresses that defendant or her associates controlled.

On October 20, 2020, as part of the scheme to defraud
described above, defendant possessed at her residence in Perris
35 EBP debit cards issued in other people’s names in response to
UI benefits applications that she submitted or caused to be
submitted. The accounts associated with these 35 debit cards
received $790,372 in UI benefits.

At least 29 EBP debit cards issued in other people’s names
in response to UI benefits applications that defendant submitted
or caused to be submitted as part of her scheme to defraud were
mailed to defendant’s Perris residence (2 cards), defendant’s
husband’s business location (3 cards), the apartment occupied by
defendant’s mother (6 cards), a Bellflower address associated
with defendant’s family (6 cards) and addresses in Tulare (not
including the Sacramento Street address discussed below) that

were occupied by defendant’s friends (12 cards). The accounts

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Case 5:21-cr-00187-JWH Document6 Filed 09/08/21 Page 37 of 39 Page ID #:51

associated with these 29 debit cards received $596,546 in UI
benefits.

The accounts associated with other EBP debit cards issued
in response to the fraudulent applications defendant submitted
and caused to be submitted in furtherance of her scheme also
received substantial UI benefits. For example, an application
that defendant submitted falsely reported that L.M. was a
musician/tattoo artist who had lost work because of COVID-19.
The bank account associated with the EBP debit card issued as a
result of the fraudulent application defendant submitted in
L.M.’s name received $26,400 in UI benefits. As a further
example of the scheme, on July 24, 2020, defendant submitted and
caused to be submitted fraudulent applications on behalf of
seven persons. On each of these applications, defendant
provided and caused to be provided as each named claimant’s
mailing address the same address on Sacramento Street in Tulare
and provided no driver’s license number or other identifying
number. Each of these applications resulted in $21,900 in
fraudulently obtained UI benefits, for a total of $153,000. As
another example of the scheme, a false claim that defendant
submitted for P.E. resulted in losses to EDD of $25,200.

Defendant would charge the named claimants a fee for filing
the applications for UI benefits. Sometimes the named claimants
paid the fee by providing a portion of the benefits received to

defendant.

6 a
Read and Agreed co fe / hy
Case 5:21-cr-00187-JWH Document6 Filed 09/08/21 Page 38 of 39 Page ID #:52

Through this scheme, defendant caused approximately 197
fraudulent PUA claims to be filed with EDD resulting in losses
to EDD and the United States Treasury of at least $1,633,487.

Executions of the Scheme to Defraud

As executions of this scheme, defendant caused UI benefits
applications in the names of J.G. and C.G., a husband and wife,
and their sons V.G. and Jo.G., to be filed on or about May il,
2020, May 11, 2020, May 27, 2020, and August 6, 2020,
respectively. The information on the applications was false
because J.G. and C.G. were not working and thus did become
unemployed due to COVID-19; Jo.G. did not apply for UI benefits
and V.G. was employed and did not lose work due to COVID-19.
Neither J.G., C.G., V.G. or Jo.G. authorized anyone to apply for
UI benefits in his/her name. As a result of the UI benefits
applications that defendant filed and caused to be filed in
J.G., C.G., and V.G.’s names, on or about May 11, 2020, June l,
2020, and May 27, 2020, respectively, Bank of America mailed EBP
debit cards to an apartment in Paramount, California, in which
defendant’s mother was living. Each of the cards provided
access to a bank account that was funded by EDD with UI benefits
worth $21,000, $4,469 and $16,500, respectively. As a result of
the UI benefits application that defendant LLERENAS filed and
caused to be filed in Jo.G.’s name, on or about August 6, 2020,
Bank of America mailed an EBP debit card to an address in
Compton, California. This card provided access to a bank

account that was funded by EDD with UI benefits worth $21,900

7 1
Read and Agreed tot R/Ry*
Case 5:21-cr-00187-JWH Document6 Filed 09/08/21 Page 39 of 39 Page ID #:53

I have read this STATEMENT OF FACTS IN SUPPORT OF PLEA
AGREEMENT in its entirety. I have had enough time to review
this statement of facts and I have carefully and thoroughly
discussed every part of it with my attorney. I agree that this
statement of facts is sufficient to support a plea of guilty to
the charge described in the plea agreement and to establish the
Sentencing Guidelines factors set forth in paragraph 13 of the
plea agreement.

—GABRIELA LLERENAS Date
Defendant

I am GABRIELA LLERENAS’s attorney. I have carefully and
thoroughly discussed every part of this statement of facts with
my client and agree that it is sufficient to support a plea of
guilty to the charge described in the plea agreement and to
establish the Sentencing Guidelines factors set forth in

paragraph 13 of the plea agreement.

dé: Lis —K ESQ. Date

Attorney for Defendant
GABRIELA LLERENAS

8
Read and Agreed to HK [x


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