Government’s Memorandum in Aid of Sentencing — United States v. Jennifer May (No. 1:25-cr-00211, D.D.C.)

Summary

Government's Memorandum in Aid of Sentencing, Document 17, filed December 4, 2025, in United States of America v. Jennifer May, Case No. 25-CR-211 (CRC), in the U.S. District Court for the District of Columbia. The memorandum states that in late 2021 May applied for $1.5 million in COVID-19 relief aid on behalf of Next Level Partners LLC and that the government recommends 21 months' incarceration followed by three years of supervised release. It states that on July 29, 2025, the United States filed a single-count Information charging Wire Fraud, 18 U.S.C. § 1343, and that May pled guilty under a written plea agreement after an arraignment on August 27, 2025. The memorandum states that May agreed to pay back $1,490,147 to the SBA and consented to a forfeiture money judgment in the amount of $1,490,147.

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Cite this document

“Government’s Memorandum in Aid of Sentencing — United States v. Jennifer May (No. 1:25-cr-00211, D.D.C.).” Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/court-filing-d-d-c-no-1-25-cr-00211-dkt-17-d-d-c-1ae3b59759/, SHA-256 673538674745d41a20feac217a94f9b3d9fcfe655363a92461b5b58428f07c72.

Full text

Case 1:25-cr-00211-CRC Document 17 Filed 12/04/25 Page 1 of 18

UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA

UNITED STATES OF AMERICA

v. Case No. 25-CR-211 (CRC)

JENNIFER MAY,

Defendant.

GOVERNMENT’S MEMORANDUM IN AID OF SENTENCING

In late 2021, Defendant Jennifer May successfully applied for $1.5 million in COVID-19

relief aid on behalf of her small business, Next Level Partners LLC (“NLP”), not because the firm

needed those funds – it did not - but because she wished to use that money earmarked for struggling

businesses to speculate in a thinly traded cryptocurrency she was hopeful would take off. When

her speculation failed and she sustained losses of hundreds of thousands of dollars, she re-directed

the pandemic relief funds not to the actual business for which she applied, but to separate, unrelated

businesses. When that was unsuccessful as well, the Defendant admitted to the Small Business

Administration (“SBA”), the government agency responsible for administering the COVID-19

relief loan she obtained, that she was simply unable to pay nearly the entirety of the loan back.

Despite the complexities of aspects of the defendant’s scheme, at its core what she did was simple:

the Defendant fraudulently applied for funds that her business did not need and then proceeded to

gamble with the public monies she received. For her conduct, the government is recommending a

sentence of 21 months’ incarceration followed by a term of three years of supervised release. The

United States of America, by and through its attorney, the United States Attorney for the District

of Columbia, respectfully submits the following memorandum in support of its recommendation.

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I. PROCEDURAL BACKGROUND

On July 29, 2025, the United States filed a single-count Information charging the defendant

with Wire Fraud, in violation of 18 U.S.C. § 1343. See ECF No. 1. On August 27, 2025, the

defendant was arraigned on the sole count of that informant and pled guilty before this Court

pursuant to a written plea agreement with the United States. See ECF No.8. The Court set a

sentencing date of December 9, 2025, and referred the matter to the U.S. Probation Office for the

District of Columbia (“USPO”) to complete a pre-sentence investigation report. USPO completed

its final report and recommendation on December 1, 2025. See ECF Nos. 15-16.

II. FACTUAL BACKGROUND

In support of his plea of guilty, the Defendant agreed to and acknowledged the following

factual proffer.

1. Jennifer May resided in Washington, D.C.

2. May was the sole owner of Next Level Partners, LLC (“NLP”) a consulting firm
based in Washington, D.C., which specialized in assisting congressional and
presidential campaigns in complying with regulations promulgated by the Federal
Election Commission and managing their accounts payable function for them.

3. May maintained several accounts, both personally and for NLP, at Bank of
America.

4. May also maintained personal accounts at BlockFi and Coinbase, two
cryptocurrency exchanges.

5. In response to the COVID-19 pandemic, the SBA offered certain entities, including
small business owners, Economic Injury Disaster Loans (“EIDL”). These loans
were provided directly from the SBA and were low-interest, fixed-rate, long-term
loans. EIDL loan proceeds could be used for working capital to make regular
payments for operating expenses, including payroll, rent/mortgage, utilities, and
other ordinary business expenses, and to pay business debt.

6. Prior to the application at issue, May had previously applied for and received
$499,000 in EIDL funds on behalf of NLP.

7. On October 21, 2021, May applied for a second modification to the original loan
amount, asking for an additional $1,500,000 in funds for NLP. In doing so, May
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agreed to be bound by the terms of the Amended Loan Authorization and
Agreement, under which she represented that she would “use all the proceeds of
this Loan solely as working capital to alleviate economic injury caused by disaster
occurring in the month of January 31, 2020 and continuing thereafter…” for the
entity on behalf of which she applied, NLP.

8. On November 8, 2021, with NLP’s EIDL second modification application still
pending, May sent an email to an SBA customer service representative in
connection with this application asking “Is there anything I need to do.? I thought
the loan would have been distributed by now. Please let me know. I need to make
payroll.”

9. Yet at the time of making these representations in her application to and subsequent
communications with the SBA, May did not intend to use the second modification
to her original EIDL application for working capital and payroll purposes. Rather,
May initially sought to use these proceeds to speculate in cryptocurrencies she had
been researching in the months and weeks leading up to her application, including
one token in particular – Tomb, which is traded on the Fantom Blockchain.
Moreover, by submitting the application and emailing the SBA representative, both
of which contained her false representations, May caused interstate wire
transmissions.

10. On November 24, 2021, the SBA disbursed $1,500,000 into NLP’s Bank of
America account controlled by May. On that same day, May transferred $775,000
from NLP’s Bank of America Account and sent to it to her own personal checking
account.

11. In addition, also on November 24, 2021, May transferred another $100,000 –
broken up into four tranches of $25,000 – through four separate accounts she
controlled, many of which had little to no activity prior to the transfers, to that same
personal checking account mentioned supra at ¶ 10.

12. On that same day – November 24, 2021 – May transferred $75,000 in EIDL
proceeds from her personal checking account and deposited it into her Coinbase
account, after which, through a series of transactions involving different
cryptocurrencies, she purchased a variety of tokens, including Tomb.

13. Also on November 24, 2021, May transferred $750,000 into her BlockFi account,
through which, again, she conducted a series of cryptocurrency transactions to
obtain Tomb on the Fantom blockchain.

14. May ultimately sustained losses of approximately $446,296.93 in her speculation
on Tomb and other cryptocurrencies. In March 2022, May ultimately transferred
out what remained of her EIDL funds in BlockFi, consisting of one tranche of
$133,639.37 and another of $161,625.00, to a separate Bank of America account.
She then used the remaining EIDL proceeds for the purpose of consummating a
purchase of a restaurant / bar / childcare space known as The Lane at Ivy City in

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Northeast Washington, D.C. The Lane at Ivy City was wholly and completely
operationally unrelated to NLP. Indeed, in and around this time, May
communicated with another individual that she was using EIDL funds for NLP not
for that business (NLP) as promised in her applications and modifications, but to
fund this venture (The Lane).

15. Further, approximately $81,492.96 in additional EIDL funds which remained in her
NLP Bank of America account were also transferred to an escrow account held by
a Virginia-based title and settlement company to fund the purchase of an unrelated
commercial real estate property in Middleburg, Virginia. The purpose of this
purchase was for May and a business partner to find a location to house computer
hardware that would facilitate the mining of cryptocurrency. This venture was
completely operationally unrelated to NLP, the entity for which May had applied
for EIDL funds in October 2021.

16. May did not repay the EIDL as required, and her EIDL became delinquent.

17. On January 17, 2023, SBA representatives began attempting to contact May
regarding her delinquent EIDL. These attempts continued every few days,
sometimes occurring multiple days in a row, until contact was finally made with
May on April 5, 2023. May informed the representative that she completed a
payment via the portal while on the phone with the representative, in the amount of
$9,853, and would make another payment soon. When she asked about hardship
deferment options, May was told that she could not be more than 60 days past due
to qualify. Following this interaction, the loan continued in delinquency and SBA
representatives attempted to contact May every few days. On November 6, 2023,
a representative successfully reached May and May told the representative that she
had no money to pay the EIDL.

18. Overall, within six days of the EIDL funds being disbursed into NLP’s Bank of
America account, approximately $1,194,200.00 was transferred out of it by May to
other, unrelated accounts which she herself personally controlled. (Specifically,
the beginning balance of NLP’s Bank of America account on November 1, 2021
was $11,229.12 and, in addition to the EIDL funds, there were only $13,457.87 in
additional funds deposited into that account during the month of November.)

19. The proceeds from May’s scheme that she obtained have been dissipated by her
and cannot be located upon the exercise of due diligence; have been transferred or
sold to, or deposited with, a third party; and/or have been placed beyond the
jurisdiction of the Court.

See ECF No. 9.

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III. DISCUSSION AND APPLICATION OF U.S. SENTENCING GUIDELINES AND
3553(a) FACTORS
A. Generally Applicable Legal Principles

When determining the appropriate sentence, the district court should consider all of the

applicable factors set forth in 18 U.S.C. § 3553(a). See United States v. Gall, 128 S. Ct. 586, 596

(2007). The listed factors in 18 U.S.C. § 3553(a) include the following:

(1) the nature and circumstances of the offense and the history and
characteristics of the defendant;

(2) the need for the sentence imposed –

(A) to reflect the seriousness of the offense, to
promote respect for the law, and to provide just
punishment for the offense;

(B) to afford adequate deterrence to criminal
conduct;

(D) to provide the defendant with needed educational
or vocational training, medical care, or other
correctional treatment in the most effective manner;

(3) the kinds of sentences available;

(4) the kinds of sentence and the sentencing range established for –

(A) the applicable category of offense committed by
the applicable category of defendant as set forth in
the guidelines –

(i) issued by the Sentencing Commission ...;
and

(ii) that, . . . are in effect on the date
the defendant is sentenced; ...

(5) any pertinent policy statement –

(A) issued by the Sentencing Commission ... and

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(B) that, . . . is in effect on the date the defendant is
sentenced.

(6) the need to avoid unwarranted sentence disparities among
defendants with similar records who have been found guilty of
similar conduct; and

(7) the need to provide restitution to any victims of the offense.

B. Guidelines Calculations

Turning to 3553(a)(4)(A), for the reasons set forth in its response to the Pre-Sentence

Investigation Report (hereinafter, “PSR”), the government agrees with the calculations of U.S.

Probation regarding the defendant’s Total Offense Level under the U.S. Sentencing Guidelines

(hereinafter, “Guidelines”), with the exception of the two-level enhancement under USSG

§2Bl.l(b)(12), for the reasons it has already stated on the record in its November 14, 2025 letter to

USPO. See ECF No. 14. The government also agrees with USPO’s calculation of Ms. May’s

criminal history. As such, the government’s calculations of the Defendant’s sentencing range

under the USSG differ only minimally from that of USPO’s.

1. Total Offense Level

The Guideline for a violation of 18 U.S.C. § 1343 is § 2B1.1, which provides for a base

offense level of 7 in cases such as this one in which the statutory maximum is at least 20 years’

incarceration. See PSR at ¶ 6. In addition, because the amount which the Defendant

misappropriated is $1,490,147, the loss amount is between $550,000, but less than $1.5 million,

which results in a 14-level increase to the base offense level. See id. at ¶ 7. As noted above, the

United States disagrees with the application of the specific offense characteristic involving 18

U.S.C. § 1040 and stands by the arguments made in ECF No. 14. 1 That leaves an adjusted offense

1
In response to the USPO’s December 1, 2025 Addendum, the government would note that in U.S. v. Chen, 24-cr-
50, the United States did not ultimately seek to apply the enhancement at issue in this case.

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level of 21. Because the defendant meets the criteria set forth in §4C1.1 for a “Zero-Point

Offender,” her offense level is reduced by two levels. Id. at ¶ 45. Furthermore, in light of her

early guilty plea pursuant to an information, she has clearly demonstrated acceptance of

responsibility, entitling her to an additional three-level decrease. Id. at ¶¶ 43-44. As such, her

Total Offense Level is 16.

2. Criminal History

The government agrees that the Defendant has no known criminal convictions and as such

has a criminal history score of zero, resulting in the Defendant being in Criminal History Category

(“CHC”) I.

3. USSG Range

In CHC 1, with a Total Offense Level of 16, the defendant’s Guidelines range is 21-27

months in Zone D. In Zone D, the minimum term may be satisfied only by incarceration. See

USSG § 5C1.1(f).

C. Recommendation

After calculating the applicable Guidelines range, the Court should next consider all of the

applicable factors set forth in 18 U.S.C. § 3553(a), noted supra at III.A. Indeed, the Guidelines

themselves are designed to calculate sentences in a way that implements the considerations

relevant to sentencing as articulated in Section 3553(a). Rita v. United States, 127 S. Ct. 2456,

2463 (2007). The Court must impose a sentence that is sufficient but not greater than necessary

to reflect the seriousness of the offense, to promote respect for the law, to provide just punishment,

to afford adequate deterrence, to protect the public from further crimes of the defendant, and to

provide the defendant with needed educational or vocational treatment. 18 U.S.C. § 3553(a)(2).

The United States recommends that the Court sentence the defendant to a term of incarceration of

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21 months, which, as detailed below, will best effectuate the purposes of sentencing as outlined in

§ 3553(a).

1. Nature and Circumstances of the Offense

The Defendant’s conduct in this case was particularly brazen. She falsely represented to

the SBA that she would use $1.5 million in public EIDL money designed to help small businesses

stay afloat during a global pandemic for the benefit of her own small business, but, instead, quickly

and methodically put those funds in service of the only goal she ever had: her own self-enrichment.

By brief way of background, the Defendant had previously received two separate tranches

of EIDL funds in 2020 and earlier in 2021. She later applied for a third tranche, this time upping

the requested amount to $1.5 million. She then frequently followed up on the status of her funds

which, she insisted, were desperately needed for her business. See Figures 1 and 2 below.

The funds were disbursed on November 24, 2021 and credited to the Bank of America

account operated and maintained by the Defendant on behalf of NLP, ending in 1873. Yet almost

immediately upon receiving these funds, though, the Defendant quickly whisked the money out of

her business’s account and into her personal account (ending 0742) or those pertaining to unrelated

business ventures. From there, $855,000 was poured into accounts she maintained at online

cryptocurrency exchanges either the same day she received the funds, November 24, 2021, or two

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days later, November 26, 2021, after the Thanksgiving holiday. The below chart summarizes the

activity in question.

Of particular note was the way in which the Defendant structured the transactions. While

a substantial portion of the funds were routed directly to her personal account -0742 that very day,

the Defendant also attempted to break up additional EIDL proceeds into tranches of $25,000,

which she routed through four separate accounts, three of which (Solidarity HR, Upland Realty,

and Mabel Properties), up until that point, had very little activity in them. After being funneled

through the four accounts, the funds were then moved directly into her personal account, with no

discernible, legitimate purpose for having been routed this way.

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The Defendant then moved the money out of her personal bank account and into her

accounts on BlockFi and Coinbase. From there, after a series of transactions, the Defendant ended

up purchasing large quantities of a token named FTM on the blockchain Multichain Fantom

Bridge, on November 26, 2021. These purchases were not based on a momentary whim as the

Defendant had spent months discussing the prospects of this token with at least one other employee

with NLP, as demonstrated in the exchanges screenshotted in Figure 3 below.

Nevertheless, ultimately her speculation failed and the Defendant ended up sustaining

losses of almost $446,000 in total. Yet that did not deter her from taking what she had left after

her failed cryptocurrency speculation and putting it into yet another business venture –the purchase

of an existing business known as “The Lane at Ivy City,” (hereinafter “The Lane”) which operated

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as a bar, café, and child care center, among other things, in the Ivy City neighborhood in

Washington, D.C. In March 2022, she cashed out almost $300,000 from her BlockFi account

alone (Figure 4) and put that into a separate bank account designed to finance her new venture

(Figure 5), before the money ultimately went to an escrow account of the attorney the Defendant

and her business partner used for the purchase (Figure 6).

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Thereafter, once the business was up and running, she continued to use EIDL proceeds to make

payments to vendors. The Lane was wholly and completely operationally unrelated to the

Defendant’s business at NLP and there was no overlap between the two. The Defendant made

little attempt to hide what she was doing and where this money was coming from, as shown in a

screenshot of an exchange with an associate captured in Figure 7 below.

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Finally, in and around that same time, in February 2022, the defendant took what remained

of the EIDL proceeds and purchased a commercial property in Middleburg, Virginia. The

downpayment on the commercial property was funded in part by at least $81,000 in proceeds from

her EIDL loan. This new commercial property was not for the purpose of setting up a satellite

office for NLP – which by that point was operating largely remotely – nor did it have anything to

do with NLP’s business operations.

Throughout 2023, the SBA made various attempts to collect on the outstanding EIDL debt

that the Defendant had incurred, but beyond a small payment of just under $10,000 in April 2023,

the Defendant never made any effort toward actually repaying the loan. In November 2023, the

SBA made one final effort at calling her and attempting to collect, but on that very phone call, she

explained she did not have the means to repay, after which the agency wrote off the loan.

In essence, the Defendant made a long-term financial play which involved using public

monies not for their designated purpose, but for her own, personal investments, perhaps believing

that she would be successful in such ventures and able to repay the government with ease and

retain whatever profit remained. When those plans came to naught, she simply declared she could

not pay anymore and left the SBA, and by extension, taxpayers, footing the bill for her ill-

conceived investments obtained through fraud. In the Defendant’s scheme, the profits were to

accrue only to her, while any losses suffered would be borne by everyone else but her.

Furthermore, while the government has not argued for the §2B1.1(b)(12) enhancement and

does not believe it applies, the government very much does believe that this Court can take into

account the overall context in which Defendant May’s fraud occurred. The COVID-19 pandemic

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represented a severe threat to the vitality of small businesses across the country. In response to

this nearly unprecedented threat to the livelihood of such firms, the SBA declared the pandemic to

be an emergency and allowed businesses to apply for up to $2 million in loans at low-interest rates

when credit would otherwise not be available, while also allowing them generous repayment plans

to ensure loan repayments did not subsequently bankrupt them. “SBA to Provide Disaster

Assistance Loans for Small Businesses Impacted by Coronavirus (COVID-19),” March 16, 2020,

available at https://www.sba.gov/article/2020/mar/16/sba-provide-disaster-assistance-loans-

small-businesses-impacted-coronavirus-covid-19. The Defendant took advantage of the

program’s openness and generosity during a time in which so many businesses needed government

support to survive and attempted to use those specially earmarked funds as “seed money” for a

variety of other business ventures. Not only did her fraud divert resources that could have been

better allocated toward businesses in actual need of government support, but it also undermined

the integrity of the program as a whole.

2. History and Characteristics

The Defendant’s history and characteristics do not readily reveal any reason why she would

have been mentally or emotionally unable to avoid her criminal conduct in this instance, but rather

suggest that she did what she did because she thought it would be profitable and could get away

with it. While defendant’s childhood and early adulthood were not without their challenges, she

appeared to thrive as a young professional in this community. The Defendant received a bachelor’s

degree as well as a Master’s in Business Administration, see PSR at ¶¶ 77-78. The Defendant then

went on to build a successful small business from the ground up in Washington, D.C., employing

up to 25 individuals at its height, id. at ¶ 82, with a reported sales amount of $792,000 as of 2025,

id. at ¶ 84. In short, the Defendant was a successful, self-employed small businesswoman whose

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company appeared to generate revenue and create jobs within the community. There was no

compelling financial need for the Defendant to take $1.5 million in EIDL funds for her already

successful business and immediately divert them for other purposes. Rather, the only logical

conclusion that can be left to draw is that the Defendant saw an opportunity for even greater profits,

with little risk (having offloaded that to the government), and seized it.

Balanced against these factors is the fact that the defendant has accepted responsibility for

her misconduct. Indeed, she did so at essentially the earliest opportunity, having waived her right

to be indicted and reached an agreement with the government before that ever became necessary.

Moreover, the government would note, to the defendant’s credit, that she debriefed with the

government and during that time ultimately admitted to her own conduct. While the government

is not making a motion pursuant to §5K1.1 based on those discussions, the defendant’s actions

upon being alerted to the government’s investigation, from coming in and meeting with the

investigation team to pleading at the earliest opportunity, do underscore her willingness to accept

her punishment and move on with her life.

3. Need for Sentence Imposed

The government believes that its proposed sentence of 21 months’ incarceration will best

effectuate the purposes of sentencing as set forth in 3553(a)(2)(A)-(D), that is, for the sentence

imposed to reflect the seriousness of the offense, promote respect for the law, and provide just

punishment for the offense; afford adequate deterrence of criminal conduct; protect the public from

further crimes of the defendant; and allow the defendant with training, treatment, and other type

of care she may require. The government believes that its recommendation of a sentence at the

bottom of the defendant’s properly calculated Guideline range accomplishes all of these goals.

The defendant’s conduct in this case, as described above, is serious: she defrauded the government

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into giving her $1.5 million in supposed disaster recovery funds for her small business with no

intent to actually use those funds for their approved purposes at the time of her application. The

Defendant then, essentially, gambled away hundreds of thousands dollars in those funds as she

attempted to ride short-term spikes in the value of an obscure cryptocurrency token. After she

sustained heavy losses on such speculation, the Defendant was not chastened into stopping her

improper use of public funds but doubled down by pouring additional money into her other

business ventures which bore absolutely no connection to the business for which she applied for

the money. A non-carceral sentence of the type recommended by USPO fails to adequately capture

the scale of her offense ($1.49 million in losses), the sheer brazenness of the scheme, including

her casual admission to a colleague that she was repurposing the EIDL funds designated for NLP

for a wholly separate business venture, and the context in which her fraud occurred. On the other

hand, the government’s recommendation of a 21-month carceral sentence underscores the

seriousness of the offense and takes into account all of those factors.

As important is the Court’s consideration of the possible deterrent effect that a sentence in

this matter may have on others contemplating committing this type of fraudulent scheme. Section

3553(a) is not limited to the necessary sentence to deter the defendant from engaging in further

criminal conduct (specific deterrence), but also includes consideration of deterring other potential

criminals from engaging in similar conduct (general deterrence). See, e.g., United States v.

Phinazee, 515 F.3d 511, 515-16 (6th Cir. 2008) (“The plain language of the statute . . . also

militates against limiting the authority of the court to specific deterrence. . . . We note that this

conclusion comports with the longstanding and uncontroversial practice of considering general

deterrence in sentencing.”). From the standpoint of general deterrence, a non-carceral sentence

will have very little deterrent effect on others and would suggest that obtaining public funds under

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false pretenses, immediately using them for your own benefit, and then leaving the government

with the bill will merely result in a long period of mere supervision. Rather, the government’s

proposed sentence of 21 months of incarceration will send a strong message to all who seek to

defraud that such acts will not be tolerated, and that rather than being supervised in the comfort of

your own residence, would-be perpetrators will be removed from the community altogether.

4. Avoiding Unwanted Sentencing Disparities

A sentence of 21 months’ incarceration is well in-line with sentences in other cases within

this District and others involving similar loss amounts and would not lead to unwarranted

sentencing disparities. Such cases would include the following:

• United States v. Zhong Chen (24-cr-50 (CRC)): 18 month-sentence for
misappropriation of portion of approximately $348,000 in EIDL proceeds to engage
in day-trading2

• United States v. Wendy Villatoro (24-cr-446 (CJN)): 15 month-sentence for PPP
fraud defendant (and public official) who made material misstatements on loan
applications involving approximately $844,000.

• United States v. Gholam Kowkabi (23-cr-193 (RBW)): 57 month-sentence for fraud
involving more than $ 1.6 million in COVID-19 relief funds as well as tax evasion
involving $1.35 million in unpaid taxes

• United States v. James Kyle Bell (21-cr-284 (JDB)): 46-month sentence for
defendant who pled to both wire fraud charges arising from a so-called scam PAC
scheme as well as fraudulently applying for $1.6 million in PPP funds.
Furthermore, the JSIN itself reveals that for individuals sentenced with similar offense

levels under §2B1.1 as well as criminal histories to that of the Defendant, the median sentence

was 18 months and the average sentence was 19 months. See PSR at ¶ 140.

2
As this Court is well aware, Defendant Chen had a different criminal history which included a prior conviction for
a violent felony in D.C. Superior Court.

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5. Restitution and Forfeiture

With respect to restitution, the crime of wire fraud is an “offense against property under”

Title 18, and thus fall under the Mandatory Victim Restitution Act, 18 U.S.C. § 3663A. As a

result, the Court must order that “the defendant make restitution to the victim of the offense[s].”

18 U.S.C. § 3663A(a)(1). In this case, the Defendant, by virtue of her plea agreement, has agreed

to pay back $1,490,147 to the SBA. The government will provide the relevant address / point of

contact at the SBA to the Clerk’s Office.

With respect to forfeiture, the Defendant has consented to the entry of a forfeiture money

judgment in the amount of $1,490,147, in this case. The government will furnish a copy of a

signed consent order to the Court for entry on the docket in advance of sentencing.

IV. CONCLUSION

WHEREFORE, for the foregoing reasons, the government respectfully recommends that

this Court sentence the Defendant to a term of 21 months’ incarceration, followed by 36 months

of supervised release.

Respectfully submitted,

JEANINE FERRIS PIRRO
UNITED STATES ATTORNEY

________________________
WILL HART
Assistant United States Attorney
U.S. Attorney’s Office for the
District of Columbia
D.C. Bar No. 1029325
601 D. St., N.W.,
Washington, D.C. 20530
William.hart@usdoj.gov
(202)-252-7877

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SHA-256: 673538674745d41a20feac217a94f9b3d9fcfe655363a92461b5b58428f07c72
Our copy: 17.pdf
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