Motion for Preliminary Order of Forfeiture — United States v. Sky Tiffany Lawson (D. Md., Dkt. 350)

Summary

United States' Motion for Preliminary Order of Forfeiture, filed April 17, 2025 as Document 350, Case 1:22-cr-00219-BAH, United States v. Sky Tiffany Lawson, District of Maryland. It states that a Superseding Indictment returned November 30, 2022 charged the Defendant with Conspiracy to Commit Wire Fraud (Count One), Wire Fraud (Counts Two through Thirty-Four) and Aggravated Identity Theft (Count Thirty-Eight), and that on January 22, 2025 the Defendant pled guilty to Counts One and Thirty-Eight. It seeks a forfeiture money judgment of $25,000.00 and permission to conduct discovery to identify, locate, or dispose of forfeited property. A footnote states the plea agreement listed at least $34,000.00 and the parties then agreed to $25,000.00.

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       Case 1:22-cr-00219-BAH           Document 350       Filed 04/17/25     Page 1 of 3



                       IN THE UNITED STATES DISTRICT COURT
                          FOR THE DISTRICT OF MARYLAND

 UNITED STATES OF AMERICA                       *
                                                *
        v.                                      *    CRIMINAL NO. BAH-22-219
                                                *
 SKY TIFFANY LAWSON,                            *
                                                *
                Defendant                       *
                                                *
                                             *******

     UNITED STATES’ MOTION FOR PRELIMINARY ORDER OF FORFEITURE

       The United States of America, by its undersigned attorneys, respectfully moves this Court

for the issuance of a Preliminary Order of Forfeiture in the above-captioned case pursuant to 18

U.S.C. § 981(a)(1)(C), 28 U.S.C. § 2461(c), and Rule 32.2(b) of the Federal Rules of Criminal

Procedure. A proposed Preliminary Order of Forfeiture is submitted herewith. In support

thereof, the United States sets forth the following:

       1.      On November 30, 2022, a federal grand jury sitting in the District of Maryland

returned a Superseding Indictment, charging Sky Tiffany Lawson (the “Defendant”) with

Conspiracy to Commit Wire Fraud, in violation of 18 U.S.C. § 1349 (Count One), Wire Fraud, in

violation of 18 U.S.C. § 1343 (Counts Two through Thirty-Four), and Aggravated Identity Theft,

in violation of 18 U.S.C. § 1028A(a)(1) and (c)(5) (Count Thirty-Eight). ECF No. 97.

       2.      The Superseding Indictment also included a forfeiture allegation which provided

notice that the United States intended to seek forfeiture, pursuant to 18 U.S.C. § 981(a)(1)(C) and

28 U.S.C. § 2461(c), upon conviction of the Defendant of the offenses alleged in Counts One

through Thirty-Four of the Superseding Indictment.

       3.      On January 22, 2025, the Defendant pled guilty to the offenses alleged in Counts

One and Thirty-Eight of the Superseding Indictment. ECF No. 306. As part of her guilty plea,
       Case 1:22-cr-00219-BAH          Document 350         Filed 04/17/25      Page 2 of 3



the Defendant agreed to entry of an order of forfeiture to include a money judgment in the amount

of at least $25,000.00 in U.S. currency equal to the value of the property derived from, or otherwise

involved in, the Defendant’s offenses. 1 Id. ¶ 12.

       4.      In support of his guilty plea, the Defendant executed a Stipulation of Facts in which

the Defendant admitted that between approximately March 2020 and October 2021, the Defendant

knowingly and willfully conspired and agreed with others to commit wire fraud by devising and

executing a scheme to defraud the United States, multiple financial institutions, and multiple states

by filing fraudulent unemployment insurance claims using the personally identifying information

of victims and obtaining money. ECF No. 306. The Defendant obtained $25,000.00 from

participating in the conspiracy.

       5.      Pursuant to 18 U.S.C. § 981(a)(1)(C), 28 U.S.C. § 2461(c), and Rule 32.2(b)(2) of

the Federal Rules of Criminal Procedure, the United States is now entitled to a forfeiture money

judgment in the amount of $25,000.00 in U.S. currency against the Defendant.

       6.      Further, the United States may move at any time, pursuant to Rule 32.2(e)(1)(B) of

the Federal Rules of Criminal Procedure and 21 U.S.C. § 853(p), to forfeit any property of the

Defendant up to the value of the forfeiture money judgment included in the Preliminary Order of

Forfeiture. Upon issuance of any order forfeiting specific property, the United States will publish

notice in accordance with 21 U.S.C. § 853(n)(1) and Rule 32.2(b)(6) of the Federal Rules of

Criminal Procedure.




1
  As part of her guilty plea, the Defendant agreed to entry of an order of forfeiture to include a
money judgment in the amount of at least $34,000.00. ECF No. 306 at ¶ 12. However, after
entering into the plea agreement, the parties conferred further and agreed that the money judgment
amount to be listed in the order of forfeiture should be $25,000.00, instead of the $34,000.00
agreed to as part of her plea agreement. Id. The Defendant has consented to the amount set forth
in this motion and the proposed order.


                                                 2
       Case 1:22-cr-00219-BAH           Document 350         Filed 04/17/25      Page 3 of 3



       7.      The United States also seeks permission to conduct any discovery that might be

necessary to identify, locate, or dispose of forfeited property, pursuant to Rule 32.2(b)(3) of the

Federal Rules of Criminal Procedure and 21 U.S.C. § 853(m).

       WHEREFORE, the United States requests that this Court:

       (a)     enter the Preliminary Order of Forfeiture in the form submitted herewith;

       (b)     include the forfeiture, as set forth in the Preliminary Order of Forfeiture, in the oral

pronouncement of the Defendant’s sentence;

       (c)     retain jurisdiction for the purpose of enforcing the forfeiture; and

       (d)     incorporate the Preliminary Order of Forfeiture in the criminal judgment entered

against the Defendant, pursuant to Federal Rule of Criminal Procedure 32.2(b)(4).



                                                      Respectfully submitted,

                                                      Kelly O. Hayes
                                                      United States Attorney

                                              By:     /s/
                                                      Colleen Elizabeth McGuinn
                                                      Assistant United States Attorney




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