Plea Agreement — United States v. Medard Ulysse (D. Md.)

Summary

A plea agreement letter dated July 22, 2022 from the United States Attorney's Office for the District of Maryland to defense counsel Richard B. Bardos in United States v. Medard Ulysse, Criminal No. RDB-21-54, filed 09/23/22 as Document 129 in Case 1:21-cr-00054-RDB. The defendant agrees to plead guilty to Count One of the Indictment, conspiracy to commit mail fraud under 18 U.S.C. § 1349, and to a separate information charging wire fraud under 18 U.S.C § 1343, each carrying a maximum of 20 years. The parties stipulate guideline factors, including a 16-level increase for a loss between $1,500,000 and $3,500,000, and a total anticipated adjusted offense level of 27, 28, or 29. The attached statement of facts states that fraudulent unemployment insurance applications funded at least $618,767 in benefits.

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