Pandemic Darlings The pandemic economy, in original documents
Home Source documents Court filing — No. 1:23-cr-00412 (Dkt. 41, D. Md.)

Court filing — No. 1:23-cr-00412 (Dkt. 41, D. Md.)

Full text

         Case 1:23-cr-00412-MJM           Document 41        Filed 10/31/25     Page 1 of 11



                          THE UNITED STATES DISTRICT COURT
                           FOR THE DISTRICT OF MARYLAND

UNITED STATES OF AMERICA                           :
                                                   :
          v.                                       : Crim. Nos. MJM-23-411, MJM-23-412
                                                   :
LAKEISHA PARKER,                                   :
                                                   :
          Defendant.                               :
                                                   :
                                              *********

                       GOVERNMENT SENTENCING MEMORANDUM

           The United States of America, by and through Kelly O. Hayes, United States Attorney

    for the District of Maryland, and Harry M. Gruber, Bijon A. Mostoufi, and Jared M. Beim,

    Assistant United States Attorneys, moves this Court to sentence Defendant Lakeisha Parker

    (“Parker” or “Defendant”) to 48 months’ incarceration in the Bureau of Prisons (“BOP”),

    supervised release of three years, restitution of $8,306,930.95,1 and a $200 special assessment.

                                       The Defendant’s Crimes

          According to the factual stipulation in her plea agreement, from in or about 2019 to on or

about November 2023, Parker participated in a money laundering conspiracy involving Yahya

Sowe, a/k/a “Cash” (“Sowe”), Kevin Colon, Adanegbe Gift Osemwenkhae (“Gift”), Victor Killen,

and others. ECF 237-1 at 1 (MJM-23-411), Attachment A at 1 (“Factual Stipulation”). The

money that Parker knowingly laundered came from a variety of frauds, including business email

compromise schemes involving the Victim College, Victim ABP, Victim AP, and the Victim

Trust, as well as COVID-19 fraud involving Economic Injury Disaster Loans (“EIDLs”) from the

U.S. Small Business Administration (“SBA”). Parker was personally involved in laundering a

very significant amount of money – more than $1 million in fraud proceeds. ECF 237-1 at 2 and


1
          The government’s restitution calculation is set forth in Exhibit 1.
                                                  1
       Case 1:23-cr-00412-MJM           Document 41      Filed 10/31/25     Page 2 of 11



6 (Factual Stipulation).

       Parker’s shell entity, which she created in furtherance of the money laundering, was called

Parker Transports LLC. ECF 237-1 at 1 (Factual Stipulation). Parker opened numerous related

bank accounts under the Parker Transports LLC facade, including a Bank of America account

ending in 1316 (“BOA 1316”), a Citibank account ending in 0305 (“Citi 0305”), a JP Morgan

Chase account ending in 5057 (“JPMC 5057”), a SunTrust/Truist account ending in 9281 (“Truist

9281”), and a Woodforest account ending in 1211 (“Woodforest 1211”). Parker and her co-

conspirators then used these accounts and accounts controlled by others in the conspiracy to

launder fraud funds. See id. The purpose of the conspiracy was to promote the underlying frauds

and conceal and disguise the fraud proceeds. Id. at 1-2.

       Parker worked on behalf of the larger money laundering conspiracy coordinated in the

Baltimore-Washington region by Gift and Sowe. Parker communicated with the other members

of the conspiracy through encrypted messaging apps, working closely with Gift in particular.

Parker provided her Parker Transports LLC business account to other members of the conspiracy

so that they could collect fraud proceedings. Following directions, Parker kept a portion of the

fraud funds for herself before engaging in multiple financial transactions in quick succession.

ECF 237-1 at 2 (Factual Stipulation).

       Bank account holders, such as Parker, used Telegram and WhatsApp to provide higher-ups

such as Gift and Sowe with images of the financial transactions they were conducting. This was

a method of controlling the individuals working with them and ensuring that persons such as Parker

carried out their designated laundering.

SBA COVID-19 Fraud

       In furtherance of the COVID-19 fraud, Parker provided Gift and other co-conspirators with

information about her Parker Transports LLC accounts. Co-conspirators submitted fraudulent

                                                2
       Case 1:23-cr-00412-MJM         Document 41        Filed 10/31/25     Page 3 of 11



EIDL applications on behalf of different persons and shell entities. Though Parker is not alleged

to have submitted or filed the applications, Parker was essential to the success of the scheme.

Parker’s accounts not only received layered SBA proceeds, but they received SBA funds directly.

As shown below, Parker’s account directly received a substantial amount of money directly from

the SBA.

       June 2020 PNC 2986 Monthly Statement




       September 2020 Woodforest 1211 Monthly Statement




       The accounts controlled by Parker through her shell entity, Parker Transports LLC,

received over $550,000 in EIDL fraud proceeds. ECF 237-1 at 6. Parker also was willing to

engage in foreign wire transfers by sending money to China. Id. In a July 2020 transfer to China,

Parker lied to PNC Bank, claiming that the purpose of the $45,000 transfer was to purchase a truck

when she knew then and there that was false. Id. Federal agents also found evidence that in

August 2020, Parker tried to send $40,000 to China, and provided false information to the bank

about the purpose of the attempted transfer, which the bank figured out did not make sense based

on the entity receiving the funds:




Parker also engaged in voluminous cash withdrawals and converted fraud funds to cashier’s

                                                3
       Case 1:23-cr-00412-MJM           Document 41       Filed 10/31/25      Page 4 of 11



checks, further helping to conceal the frauds and fraud proceeds. Id.

       In addition to the SBA fraud, Parker personally laundered substantial amounts of money

belonging to four institutions—Victim College, Victim ABP Fraud, Victim Company AP, and the

Victim Trust—many of which were focused on doing good for the community.

       Victim College, a small but long-established liberal arts college, was deceived into sending

more than $400,000 to Truist 9281, which Parker controlled through Parker Transports LLC.

Parker and her co-conspirators quickly moved the money into other accounts, including other

accounts that Parker controlled like Citi 0305 and BOA 1316, $80,000 of which was layered by

transfer to JPMC 5057.     Some of the checks contained false notations in the memo line like

“Truck Purchase.”    ECF 237-1 at 3.

       Victim ABP, a 501(c)(3) organization dedicated to helping low-income communities, was

deceived into sending a wire for $2,529,320, believing it to be a legitimate business debt, to a PNC

account ending in 6379.     This account was in the name of a fake identity, but was actually

controlled by an associate of Parker.   This associate split the money between various accounts,

including sending more than $630,000 through accounts that Parker controlled.      Parker was later

captured on bank surveillance withdrawing some of these funds in cash, which she used for various

personal luxury expenses, including more than $4,800 at Apple in Towson, Maryland and over

$8,500 at RK Luxury Jewelers in Baltimore, Maryland. See id.

       Parker also furthered the conspiracy by conducting wire transfers and calling Bank of

America to inquire about which branches would allow her to purchase cashier’s checks.          ECF

237-1 at 3-4.

       Victim AP, a small LLC, was deceived into sending roughly $1.1 million, believing it to

be a legitimate bill, to an account at Woodforest Bank ending in 4636.   Parker’s CashApp account

ended up receiving $8,000 from this fraud. ECF 237-1 at 4.

                                                 4
      Case 1:23-cr-00412-MJM          Document 41       Filed 10/31/25     Page 5 of 11



       Victim Trust was responsible for an important environmental clean-up project in

California, specifically working to decontaminate and deconstruct a battery recycling facility.

The Trust attempted to make payments to a vendor in connection with this project, but was

deceived into sending wires totaling over $2.7 million to a PNC account ending in 4286.    ECF

237-1 at 4. This account was controlled by Gedeon Agbeyome, and he sent these stolen funds to

multiple accounts, $16,000 of which was ultimately sent to Parker’s CashApp account. Id.

         Procedural History and The Advisory Sentencing Guidelines Calculation

       On November 16, 2023, the grand jury returned an Indictment against the Defendant and

nine other individuals, charging them with multiple criminal offenses, including conspiracy to

commit money laundering, in violation of 18 U.S.C. § 1956(h). ECF 1 (MJM-23-411), Count

One. Parker was also charged in Counts Two and Three with conducting particular money

laundering transactions, in violation of 18 U.S.C. §§ 1956(a)(1)(A), (a)(1)(B). See id. On this

same day, the grand jury returned a separate Indictment against Parker and another individual,

charging them with conspiracy to commit wire fraud, in violation of 18 U.S.C. § 1349. ECF 1

(MJM-23-412). Parker was also charged in Counts Two through Six with substantive counts of

wire fraud, in violation of 18 U.S.C. § 1343. See id.

       On February 7, 2024, the Defendant had her initial appearance. ECF 29 (MJM-23-411).

The Defendant was released on conditions. ECF 61 (MJM-23-411).

       On December 5, 2024, the grand jury returned a Superseding Indictment against the

Defendant and others, including conspiracy to commit money laundering, in violation of 18 U.S.C.

§ 1956(h). ECF 153 (MJM-23-411), Count One. Parker also was charged in Counts Two, Four,

and Five with conducting particular money laundering transactions, in violation of 18 U.S.C.

§§ 1956(a)(1)(A), (a)(1)(B). Parker appeared on the Superseding Indictment on July 22, 2025,

and entered a plea of guilty to Count One of the Superseding Indictment. ECF 234-35 (MJM-23-

                                                5
       Case 1:23-cr-00412-MJM          Document 41        Filed 10/31/25      Page 6 of 11



411). Parker also appeared on the other Indictment on this date and entered a plea of guilty to

Count One of that Indictment. ECF 25 (MJM-23-412).

       Pursuant to the plea agreement, as to Count One in MJM-23-411, the parties agreed on a

base offense level of eight (8), in accordance with U.S.S.G. §§ 2X1.1, 2S1.1(a)(2). The parties

also agreed to increase the base offense level by fourteen (14) levels, pursuant to U.S.S.G.

§§ 2S1.1, 2B1.1(b)(1)(H), because the loss associated with the Defendant’s offense was more than

$550,000, but less than $1.5 million. See ECF 237 at 5 ¶ 6a (Plea Agreement); ECF 244 (MJM-

23-411), Presentence Report (“PSR”) at ¶ 35.

       The plea agreement and the PSR further calculated that the offense level should be

increased (i) by two (2) levels, pursuant to U.S.S.G. § 2S1.1(b)(2)(B), because the offense involved

a conviction under 18 U.S.C. § 1956; and (ii) by two (2) levels, pursuant to U.S.S.G. § 2S1.1(b)(3),

because the offense involved sophisticated laundering This results in a adjusted offense level of

twenty-six (26). PSR at ¶ 47.

       As to Count One in MJM-23-412, the parties agreed on a base offense level of seven (7),

in accordance with U.S.S.G. §§ 2X1.1, 2B1.1(a)(1). Plea Agreement at ¶ 6b.         The parties also

agreed to increase the base offense level by fourteen (14) levels, pursuant to U.S.S.G. §§ 2S1.1,

2B1.1(b)(1)(H), because the loss associated with the Defendant’s offense was more than $550,000,

but less than $1.5 million. Id.    The plea agreement calculated that the offense level should be

increased by two (2) levels, pursuant to U.S.S.G. § 2S1.1(b)(3), because the offense involved

sophisticated laundering. Id. This results in an adjusted offense level of twenty-three (23). Id.

       The parties agreed that pursuant to U.S.S.G. § 3Dl.2(d), both counts of conviction in MJM-

23-411 and MJM 23-412 involve substantially the same harm and should be grouped together.

Id. at ¶ 6c. Pursuant to § 3Dl.3, the final offense level is twenty-six (26) because the guidelines

for MJM-23-411 result in a higher offense level. As reflected in the PSR, the Defendant’s timely

                                                 6
       Case 1:23-cr-00412-MJM          Document 41         Filed 10/31/25      Page 7 of 11



acceptance of responsibility results in a further reduction of three levels, and an adjusted offense

level of 23. PSR at ¶¶ 41-51.

       Unlike multiple other defendants to appear before this Court, Parker has a prior criminal

history, which involves two theft convictions in 2010 and 2017. 2         The statement of charges

regarding the 2017 conviction indicates that she was attempting to steal from a vehicle parked

outside the victim’s home. When law enforcement responded, Parker was verbally abusive

toward the responding law enforcement officers. As a result of her theft convictions, Parker

should be sentenced based on a criminal history category of two, with a recommended sentence

between 51 and 63 months of incarceration.

                                The 3553(a) Sentencing Analysis

       As this Court is aware, it must impose a reasonable sentence that is sufficient but not greater

than necessary to achieve the goals of sentencing, based on multiple factors, including “the nature

and circumstances of the offense,” “the history and characteristics of the defendant,” the need “to

promote respect for the law,” the need for just punishment without unwarranted sentencing

disparities and the need for both specific and general deterrence. 18 U.S.C. § 3553(a).

       Here, the nature and circumstances of Parker’s crimes were very serious. Parker’s money

laundering was part of an extensive criminal network stretching around the globe that inflicted

significant harm on numerous victims. Parker was not a leader in the conspiracy, but she

participated in the money laundering for years and personally laundered over a million dollars.

Her money laundering involved frauds that hurt many different people and organizations. These

business email compromise schemes are greatly furthered by having a cadre of willing co-

conspirators available to deposit fraud funds, and then rapidly engage in requested financial



2
       In 2014, Parker was also convicted of driving without authorization and in 2019 of failure
to obey a lawful order, but those convictions did not result in a criminal history point increase.
                                                 7
       Case 1:23-cr-00412-MJM         Document 41       Filed 10/31/25     Page 8 of 11



transactions, such as overseas wires, cash withdrawals, purchases of cashier’s checks, and

CashApp transfers. By the time that victims realized they had been deceived and got their

financial institutions and law enforcement involved, the fraud proceeds had been layered so many

times that the funds were beyond the reach of law enforcement, banks, and the victims.

       Parker showed deliberate disregard for the legal system by knowingly joining and carrying

out her illegal activity. The role that she and others played in the money laundering conspiracy

should not be discounted or denied. Parker directly enabled and furthered the criminal conspiracy

for her own financial benefit.

       As the Court has recognized in other sentencings in this case, the new criminal conduct

Parker has now admitted has caused harm, as it involves “taking advantage of victims’

vulnerabilities” both to steal money and make it more difficult for stolen money to be recovered.

ECF 232 (MJM-23-411), Transcript of Sentencing at 33:5-8, United States v. Kevin Colon (June

20, 2025). Further, this Court has recognized that even an actor who is “not at the top of the

conspiracy” and whose “conduct consisted primarily of taking directions of others” can still

“exercise some significant degrees of discretion along the way.” Id. at 34:2-5. Acting “in

furtherance of the conspiracy several times” and contributing to “very substantial losses makes

[one’s] culpability high enough to warrant a prison sentence of appreciable length.” Id. at 34:5-

9.

       Moreover, Parker will be sentenced by this Court for having engaged in both the COVID-

19 wire fraud and the money laundering. Unlike many others appearing before this Court, Parker

directly participated in the EIDL frauds. Parker’s accounts showed multiple direct deposits from

the SBA, putting her on notice that she was involved in pandemic fraud, and she also obtained a

significant amount of additional EIDL funds after they had been layered through other accounts.

Cumulatively, Parker has stipulated that her accounts received more than $550,000 in fraudulent

                                               8
       Case 1:23-cr-00412-MJM           Document 41         Filed 10/31/25     Page 9 of 11



EIDL money.

       Parker’s history and characteristics should also be a source of concern for this Court.

Parker had eight run-ins with the law before her indictments in these cases, including four

convictions and four sets of charges that were dropped. She committed two theft offenses—years

apart from one another—that resulted in her classification as criminal history category II. She

also was convicted for driving without a license, and more recently for failure to obey a lawful

order. Woven throughout her criminal history are multiple indications that Parker has a disregard

for the law.

       Moreover, there is a need in this case for both specific deterrence due to Parker’s repeated

criminal acts, and general deterrence due to the need to put others on notice not to take the easy

money that these types of schemes offer. As this Court previously recognized, a significant period

of incarceration is necessary to fight the unfortunate “perception out there that this kind of conduct

is not that big of a deal and it’s hard to get caught.” Id. at 35:7-12.

       The government submits that a sentence of 48 months’ imprisonment would constitute a

reasonable sentence pursuant to 18 U.S.C. § 3553(a), and the Supreme Court’s decision in Gall v.

United States, 552 U.S. 38, 51 (2007). It is necessary based on “the nature and circumstances of

the offense,” “the history and characteristics of the defendant,” the need “to promote respect for

the law,” and the need for both specific and general deterrence. 18 U.S.C. § 3553(a). The

government further asks the Court to order supervised release of three years, restitution as set forth




                                                  9
      Case 1:23-cr-00412-MJM          Document 41      Filed 10/31/25     Page 10 of 11



in Exhibit 1, and a $200 special assessment.

                                                Respectfully submitted,

                                                Kelly O. Hayes
                                                United States Attorney

                                                       /s/
                                                Harry M. Gruber
                                                Bijon A. Mostoufi
                                                Jared M. Beim
                                                Assistant United States Attorneys
                                                36 S. Charles Street, 4th Floor
                                                Baltimore, Maryland 21201-2692




                                               10
      Case 1:23-cr-00412-MJM         Document 41       Filed 10/31/25     Page 11 of 11



                               CERTIFICATE OF SERVICE

       I hereby certify that a copy of the foregoing Government’s filing was served via email on

the defendant’s counsel.


                                                   ________/s/_______________
                                                   Jared M. Beim
                                                   Assistant United States Attorney




                                              11


File and source

File
41.pdf
Size
250,771 bytes
SHA-256
762e17d0d201550ddedc6b745777636121220c70d30c77617d856ff129167501
Our copy
41.pdf
Original
archive.org
Back to top