Plea Agreement — United States v. Darren Carlyle Sadler (N.D. Ill.)

Summary

A Plea Agreement filed 06/30/25 as Document #: 29 in United States of America v. Darren Carlyle Sadler, No. 25 CR 132, U.S. District Court, Northern District of Illinois, Eastern Division, Judge Thomas M. Durkin, between the United States Attorney for the Northern District of Illinois and the defendant under Rule 11 of the Federal Rules of Criminal Procedure. The agreement states that the information charges wire fraud in violation of Title 18, United States Code, Section 1343, and that the defendant agrees to plead guilty and to a forfeiture judgment. In the factual basis the defendant admits that between in or about March 2020 and December 2020 the defendant and others devised a scheme to defraud, and that in April and May of 2020 the defendant caused more than sixty PPP loan applications containing false information about employees and payroll.

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Case: 1:25-cr-00132 Document #: 29 Filed: 06/30/25 Page 1 of 24 PagelD #:52

FILED

UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF ILLINOIS JUN 80 2025
EASTERN DIVISION JUDGE THOMAS M.D
» DURKIN
U.S. D
UNITED STATES OF AMERICA ) ISTRICT COURT
) No. 25 CR 132
vs. )
) Judge Thomas M. Durkin
DARREN CARLYLE SADLER )
PLEA AGREEMENT

1. This Plea Agreement between the United States Attorney for the
Northern District of Illinois, ANDREW S. BOUTROS, and defendant DARREN
CARLYLE SADLER, and his attorney, JEFFREY C. LICHTMAN, is made pursuant
to Rule 11 of the Federal Rules of Criminal Procedure. The parties to this Agreement
have agreed upon the following:

Charges in This Case

2. The information in this case charges defendant with wire fraud, in
violation of Title 18, United States Code, Section 1343.

3. Defendant has read the charge against him contained in the
information, and that charge has been fully explained to him by his attorney.

4, Defendant fully understands the nature and elements of the crimes with
which he has been charged.

Charges to Which Defendant Is Pleading Guilty

5. By this Plea Agreement, defendant agrees to enter a voluntary plea of

guilty to the information charging him with wire fraud. In addition, as further

provided below, defendant agrees to the entry of a forfeiture judgment.
Case: 1:25-cr-00132 Document #: 29 Filed: 06/30/25 Page 2 of 24 PagelD #:53

Factual Basis

6. Defendant will plead guilty because he is in fact guilty of the charges
contained in the information. In pleading guilty, defendant admits the following facts
and that those facts establish his guilt beyond a reasonable doubt, and establish a
basis for forfeiture of the property described elsewhere in this Plea Agreement:

Between in or about March 2020 and December 2020, in the Northern District
of Illinois and elsewhere,

DARREN CARLYLE SADLER,

defendant herein, along with others including Co-Schemer A, devised, intended to
devise, and participated in a scheme to defraud and to obtain money and property by
means of materially false and fraudulent pretenses, representations, and promises.
Defendant executed this scheme on or about May 6, 2020, by causing an interstate
wire communication, namely, a communication related to the transfer of
approximately $268, 100 from Customer’s Bank into the First American Bank account
of Business Owner A, representing the proceeds of a PPP loan.

Prior to the COVID-19 pandemic, defendant owned loan brokering businesses
through which he assisted small business owners in obtaining lines of credit and
loans by acting as a middleperson between the business owners and lending
institutions in return for a fee. Defendant collected the business owners’ information

and then sought the best loan options for his business owner clients.
Case: 1:25-cr-00132 Document #: 29 Filed: 06/30/25 Page 3 of 24 PagelD #:54

In or about March 2020, following the enactment of the CARES Act, defendant,
then a resident of San Diego, California, began contacting his existing and former
clients about assisting them in obtaining PPP loans. Defendant also conferred with
Co-Schemer A, an accountant and bookkeeper residing in San Diego, California,
whose services he had utilized in the past, about the types of information and
documents that would be needed in order for defendant to submit applications and
obtain PPP loans for his clients. Together, defendant and Co-Schemer A discussed
various program requirements and devised a list of information and documents to
request from any clients interested in obtaining PPP loans.

Various existing and potential clients contacted defendant about
applying for PPP loans after receiving a solicitation email from defendant or
otherwise learning about defendant’s purported ability to help them obtain PPP
loans. At times, defendant also utilized recruiters who would refer additional clients
to defendant in exchange for a fee, including Co-Schemer B. As requested, these
existing and potential clients provided defendant with various pieces of information
and documents about their businesses, including the information and documents set
forth in the list defendant prepared with the assistance of Co-Schemer A. After
receiving this information and these documents, defendant concluded that several
clients either did not legitimately qualify for PPP loans or did not qualify for a loan
in an amount large enough to justify the fee defendant wanted to receive in return

for his services. Defendant and Co-Schemer A then discussed and decided to falsify
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the information and the supporting documents submitted on behalf of these clients
in order to make it appear that the clients employed more individuals than they
actually employed and had larger corresponding payrolls than they actually did at
their businesses. As defendant knew, the amount of a PPP loan was based upon the
average monthly payroll for a business and that there were limitations on the amount
of income that would be considered for each employee. Defendant therefore decided
to purposefully include false information that artificially inflated the number of
employees and the resulting payroll for his clients’ businesses in order to obtain PPP
loans in amounts larger than his clients were entitled to otherwise receive, if at all,
for their businesses. Co-Schemer A agreed to assist defendant in submitting these
false applications by, among other things, preparing fake documents to support the
false information about employees and payroll contained in the applications.
Defendant acknowledges that the number of employees and the payroll figures were
material to the lenders in approving and funding PPP loans. During in or about April
and May of 2020, with the assistance of Co-Schemer A and others who referred
potential clients to him, including Co-Schemer B, defendant caused the creation and
completion of more than sixty PPP loan applications for his business owner clients
containing false information regarding the number of their employees and average
monthly payroll. Defendant purposefully inflated the number of employees, if any,
working for these business as well as the amounts of payroll in these applications in

order to fraudulently increase the amount of the PPP loans for his clients. Defendant
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also caused the submission of false documents, including false payroll documents and
tax forms created by Co-Schemer A, in connection with these PPP loan applications.
Recruiters such as Co-Schemer B received a portion of the loans proceeds as a fee.

To facilitate the submission of these applications, defendant utilized
automated processes, such an application portal, and contractors to help him obtain
information from potential clients as well as to submit the PPP loan applications
along with the false documents prepared by Co-Schemer A.

In order to conceal his scheme, defendant caused the PPP loan applications to
be submitted in the names of his clients as if they were personally applying for the
PPP loans. Defendant caused the applications to be submitted utilizing virtual
private networks located in the same area as his clients in the event that the lender
captured JP address information during the application process. Defendant also
created and used unique email addresses, which often included the name of the
client’s business, to apply for the PPP loans and to communicate with the lenders as
needed. This procedure allowed defendant to control all communications with the
lenders and to conceal his scheme from others.

For example, one of the false applications that defendant caused to be
submitted was an application submitted by defendant on behalf of Business Owner
A, who owned a trucking business located in Matteson, Illinois, and wanted the PPP
loan proceeds deposited into an account held at First American Bank in Elk Grove

Village, Illinois. In April 2020, defendant prepared and submitted a PPP application
Case: 1:25-cr-00132 Document #: 29 Filed: 06/30/25 Page 6 of 24 PagelD #:57

for Business Owner A that contained materially false representations about the
number of employees and monthly payroll for Business Owner A’s trucking business.
On or about April 14, 2020, Business Owner A’s loan application was approved, based
on the loan application containing materially false representations that defendant
prepared and submitted, and on or about May 6, 2020, Customer’s Bank funded a
PPP loan in the amount of approximately $268,100 for Business Owner A by wiring
funds into Business Owner A’s First American Bank account. Defendant
acknowledges that the wiring of $268,100 involved an interstate wire communication
to facilitate the transfer from Customer’s Bank to First American Bank.

In addition to submitting false applications on behalf of clients, defendant also
submitted and obtained three fraudulent PPP loans for his own businesses, namely,
Milan Equity Group, LLC; Milan Financial, LLC; and BCOA Centers, LLC. In order
to obtain these loans, defendant submitted loan applications that falsely inflated the
number of employees and payroll for each of his businesses. Defendant also submitted
false tax forms and payroll summaries that had been prepared by Co-Schemer A in
support of these fraudulent applications. None of these businesses had any actual
employees. Defendant falsely represented the number of purported employees and
the average monthly payroll for these business in order to receive PPP loans in loan
amounts in excess of any amount he otherwise would have been entitled to receive

under the program.
Case: 1:25-cr-00132 Document #: 29 Filed: 06/30/25 Page 7 of 24 PagelD #:58

Based upon these false representations and supporting documents, defendant
caused financial institutions, namely, Customer’s Bank and Chase Bank, to fund PPP
loans to his businesses in amounts of $457,612 to Milan Financial, LLC, $380,000 to
BCOA Centers, LLC, and $453,600 to Milan Equity Group, LLC. Defendant caused
the proceeds of these loans, which exceeded $1,000,000, to be deposited into accounts
personally controlled by him and after receiving the proceeds of these loans used them
for his own personal purposes.

In total, defendant submitted and caused the submission of at least 63
fraudulent PPP loan applications resulting in the issuance of more than $14 million
in loan funds to defendant and his clients. Defendant also received in excess of $1.9
million from his clients as a fee for fraudulently obtained PPP loans on their behalf.
Defendant caused the proceeds from his loans and his clients’ loans to be deposited
in an account held in the name of the Milan Equity Group at Chase Bank. Among
other things, defendant used funds received from client fees and his own PPP loan
proceeds to rent a villa for several months during the pandemic, to travel across the
country on private jets to meet clients and appear in person at Chase bank branches
to secure fund transfers, and to purchase luxury vehicles and goods, including a Rolls
Royce coupe, a Mercedes Benz SUV, a Mercedes Benz convertible, a Land Rover,
designer clothing, a luxury watch, and numerous meals at expensive restaurants.

7. The foregoing facts are set forth solely to assist the Court in determining

whether a factual basis exists for defendant’s plea of guilty and criminal forfeiture,
Case: 1:25-cr-00132 Document #: 29 Filed: 06/30/25 Page 8 of 24 PagelD #:59

and are not intended to be a complete or comprehensive statement of all the facts
within defendant’s personal knowledge regarding the charged crimes and related
conduct.

Maximum Statutory Penalties

8. Defendant understands that the charges to which he is pleading guilty
carry the following statutory penalties:

a. Count One carries a maximum sentence of 20 years’
imprisonment. Count One also carries a maximum fine of $250,000, or twice the
gross gain or gross loss resulting from that offense, whichever is greater. Defendant
further understands that with respect to Count One the judge also may impose a term
of supervised release of not more than three years.

b. Defendant further understands that the Court must order
restitution to the victims of the offense in an amount determined by the Court.

Cc. Pursuant to Title 18, United States Code, Section 3013, defendant
will be assessed $100 on each count to which he has pled guilty, in addition to any
other penalty or restitution imposed.

Sentencing Guidelines Calculations
9. Defendant understands that, in determining a sentence, the Court is
obligated to calculate the applicable Sentencing Guidelines range, and to consider
that range, possible departures under the Sentencing Guidelines, and other

sentencing factors under 18 U.S.C. § 3558(a), which include: (i) the nature and
Case: 1:25-cr-00132 Document #: 29 Filed: 06/30/25 Page 9 of 24 PagelD #:60

circumstances of the offense and the history and characteristics of the defendant; (ii)
the need for the sentence imposed to reflect the seriousness of the offense, promote
respect for the law, provide just punishment for the offense, afford adequate
deterrence to criminal conduct, protect the public from further crimes of the
defendant, and provide the defendant with needed educational or vocational training,
medical care, or other correctional treatment in the most effective manner; (iii) the
kinds of sentences available; (iv) the need to avoid unwarranted sentence disparities
among defendants with similar records who have been found guilty of similar
conduct; and (v) the need to provide restitution to any victim of the offense.

10. For purposes of calculating the Sentencing Guidelines, the parties agree
on the following points:

a. Applicable Guidelines. The Sentencing Guidelines to be
considered in this case are those in effect at the time of sentencing. The following
statements regarding the calculation of the Sentencing Guidelines are based on the
Guidelines Manual currently in effect, namely the 2024 Guidelines Manual.

b. Offense Level Calculations.

1. The base offense level is 7, pursuant to Guideline
§ 2B1.1(a)(1).
li. The offense level is increased 20 levels, pursuant to

Guideline § 2B1.1(b)(1)(K), because the loss amount attributed to defendant’s offense
Case: 1:25-cr-00132 Document #: 29 Filed: 06/30/25 Page 10 of 24 PagelD #:61

was approximately $14,692,762, which is more than $9.5 million but less than $25
million.

iii. The offense level is increased by 2 levels, pursuant to
Guideline § 2B1.1(b)(10)(C), because the offense involved sophisticated means and
defendant engaged in conduct constituting sophisticated means.

lv. The offense level is increased by 2 levels, pursuant to
Guideline § 2B1.1(b)(17)(A), because defendant derived more than $1,000,000 in gross
receipts from one or more financial institutions as a result of the offense.

v. Defendant has clearly demonstrated a recognition and
affirmative acceptance of personal responsibility for his criminal conduct. If the
government does not receive additional evidence in conflict with this provision, and
if defendant continues to accept responsibility for his actions within the meaning of
Guideline § 3E1.1(a), including by furnishing the United States Attorney’s Office and
the Probation Office with all requested financial information relevant to his ability to
satisfy any fine or restitution that may be imposed in this case, a two-level reduction
in the offense level is appropriate.

vi. In accord with Guideline § 3E1.1(b), defendant has timely
notified the government of his intention to enter a plea of guilty, thereby permitting
the government to avoid preparing for trial and permitting the Court to allocate its
resources efficiently. Therefore, as provided by Guideline § 3E1.1(b), if the Court

determines the offense level to be 16 or greater prior to determining that defendant

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is entitled to a two-level reduction for acceptance of responsibility, the government
will move for an additional one-level reduction in the offense level.

vil. Based on the facts now known to the government,
defendant does not receive any criminal history points from Chapter Four, Part A,
and otherwise meets the criteria set forth in Guidelines § 4C1.1(a). Therefore, the
offense level is decreased by 2 levels.

c. Criminal History Category. With regard to determining
defendant’s criminal history points and criminal history category, based on the facts
now known to the government, defendant’s criminal history points equal zero and
defendant’s criminal history category is I.

d. Anticipated Advisory Sentencing Guidelines Range.
Therefore, based on the facts now known to the government, the anticipated offense
level is 26 which, when combined with the anticipated criminal history category of I,
results in an anticipated advisory sentencing guidelines range of 63 to 78 months’
imprisonment, in addition to any supervised release, fine, and restitution the Court
may impose.

e. Defendant and his attorney and the government acknowledge
that the above guidelines calculations are preliminary in nature, and are non-binding
predictions upon which neither party is entitled to rely. Defendant understands that
further review of the facts or applicable legal principles may lead the government to

conclude that different or additional guidelines provisions apply in this case.

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Defendant understands that the Probation Office will conduct its own investigation
and that the Court ultimately determines the facts and law relevant to sentencing,
and that the Court’s determinations govern the final guideline calculation.
Accordingly, the validity of this Agreement is not contingent upon the probation
officer’s or the Court’s concurrence with the above calculations, and defendant shall
not have a right to withdraw his plea on the basis of the Court’s rejection of these
calculations.

f. Both parties expressly acknowledge that this Agreement is not
governed by Fed. R. Crim. P. 11(c)(1)(), and that errors in applying or interpreting
any of the sentencing guidelines may be corrected by either party prior to sentencing.
The parties may correct these errors either by stipulation or by a statement to the
Probation Office or the Court, setting forth the disagreement regarding the applicable
provisions of the guidelines. The validity of this Agreement will not be affected by
such corrections, and defendant shall not have a right to withdraw his plea, nor the
government the right to vacate this Agreement, on the basis of such corrections.

Cooperation
11. Defendant agrees he will fully and truthfully cooperate in any matter in
which he is called upon to cooperate by a representative of the United States
Attorney’s Office for the Northern District of Illinois. This cooperation shall include
providing complete and truthful information in any investigation and pre-trial

preparation and complete and truthful testimony in any criminal, civil, or

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administrative proceeding. Defendant agrees to the postponement of his sentencing
until after the conclusion of his cooperation.
Agreements Relating to Sentencing

12. At the time of sentencing, the government shall make known to the
sentencing judge the extent of defendant’s cooperation. Ifthe government determines
that defendant has continued to provide full and truthful cooperation as required by
this agreement, then the government shall move the court, pursuant to Guideline
§ 5K1.1, to depart downward from the low end of the applicable guideline range in an
amount to be determined by the government at the time of sentencing. Defendant
shall be free to recommend any sentence.

13. If the government does not move the Court, pursuant to Guideline
§ 5K1.1, to depart from the applicable guideline range, as set forth above, the
preceding paragraph of this Agreement will be inoperative, both parties shall be free
to recommend any sentence, and the Court shall impose a sentence taking into
consideration the factors set forth in 18 U.S.C. § 3553(a) as well as the Sentencing
Guidelines without any downward departure for cooperation pursuant to § 5K1.1.
Defendant may not withdraw his plea of guilty because the government has failed to
make a motion pursuant to Guideline § 5K1.1.

14. It is understood by the parties that the sentencing judge is neither a
party to nor bound by this Agreement and may impose a sentence up to the maximum

penalties as set forth above. Defendant further acknowledges that if the Court does

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not accept the sentencing recommendation of the parties, defendant will have no right
to withdraw his guilty plea.

15. Regarding restitution, defendant acknowledges that the total amount of
restitution owed to the victims of the offense is $14,692,762, minus any credit for
funds repaid prior to sentencing, and that pursuant to Title 18, United States Code,
Section 3663A, the Court must order defendant, together with any jointly liable co-
defendants, to make full restitution in the amount outstanding at the time of
sentencing. |

16. Restitution shall be due immediately, and paid pursuant to a schedule
to be set by the Court at sentencing. Defendant acknowledges that pursuant to Title
18, United States Code, Section 3664(k), he is required to notify the Court and the
United States Attorney’s Office of any material change in economic circumstances
that might affect his ability to pay restitution.

17. Defendant agrees to pay the special assessment of $100 at the time of
sentencing with a cashier’s check or money order payable to the Clerk of the U.S.
District Court.

18. Defendant agrees that the United States may enforce collection of any
fine or restitution imposed in this case pursuant to Title 18, United States Code,
Sections 3572, 3613, and 3664(m), and Title 31, United States Code, Sections 3711,
3716, and 3728, notwithstanding any payment schedule set by the Court. In the event

of the death or dissolution of, or the government’s inability to locate the named

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recipient(s) of restitution in the Judgment and Commitment Order, the defendant
agrees to not oppose efforts by the government to obtain an order substituting as
payee a representative of the victim’s estate, another family member, or any other
person or successor entity appointed as suitable by the court, or the Crime Victims
Fund.

Forfeiture

19. Defendant understands that by pleading guilty, he will subject to
forfeiture to the United States all right, title, and interest that he has in any property
constituting or derived from proceeds obtained, directly or indirectly, as a result of
the offenses.

20. Defendant agrees to the entry of a personal money judgment in the
amount of $14,692,762, which represents the total amount of proceeds traceable to
the offense. Defendant consents to the immediate entry of a preliminary order of
forfeiture as to this specific property, thereby extinguishing any right, title, or
interest defendant has in it.

21. Defendant further agrees to waive and abandon any right, title, or
interest in $1,851,959 held in Chase Bank account x8975 in the name of Milan Equity
Group, LLC and defendant as its manager, which funds were previously frozen
pursuant to an agreed stipulation and ordered enter in Case No. 21 M 287, and shall
not oppose the treatment of such funds as substitute property, as provided in Title

18, United States Code, Section 853(p).

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22. Defendant understands that forfeiture shall not be treated as
satisfaction of any fine, restitution, cost of imprisonment, or any other penalty the
Court may impose upon defendant in addition to the forfeiture judgment. In this case,
however, the United States Attorney’s Office will recommend to the Attorney General
that any net proceeds derived from any forfeited assets be remitted or restored to
eligible victims of the offense pursuant to Title 18, United States Code, Section 981(e),
Title 28, Code of Federal Regulations, Part 9, and other applicable law.

23. Defendant agrees to waive all constitutional, statutory, and equitable
challenges in any manner, including but not limited to direct appeal or a motion
brought under Title 28, United States Code, Section 2255, to any forfeiture and/or
abandonment carried out in accordance with this agreement on any grounds,
including that the forfeiture constitutes an excessive fine or punishment. The waiver
in this paragraph does not apply to a claim of involuntariness or ineffective assistance
of counsel.

Acknowledgments and Waivers Regarding Plea of Guilty

Nature of Agreement
24. This Agreement is entirely voluntary and represents the entire
agreement between the United States Attorney and defendant regarding defendant’s
criminal liability in case 25 CR 132.
25. This Agreement concerns criminal liability only. Except as expressly set

forth in this Agreement, nothing herein shall constitute a limitation, waiver, or

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release by the United States or any of its agencies of any administrative or judicial
civil claim, demand, or cause of action it may have against defendant or any other
person or entity. The obligations of this Agreement are limited to the United States
Attorney’s Office for the Northern District of Illinois and cannot bind any other
federal, state, or local prosecuting, administrative, or regulatory authorities, except
as expressly set forth in this Agreement.
Waiver of Rights

26. Defendant understands that, by pleading guilty, he surrenders certain
rights, including the following:

a. Right to be charged by indictment. Defendant understands
that he has a right to have the charges prosecuted by an indictment returned by a
concurrence of twelve or more members of a grand jury consisting of not less than
sixteen and not more than twenty-three members. By signing this Agreement,
defendant knowingly waives his right to be prosecuted by indictment and to assert at
trial or on appeal any defects or errors arising from the information, the information
process, or the fact that he has been prosecuted by way of information.

b. Trial rights. Defendant has the right to persist in a plea of not
guilty to the charges against him, and if he does, he would have the right to a public
and speedy trial.

1. The trial could be either a jury trial or a trial by the judge

sitting without a jury. However, in order that the trial be conducted by the judge

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sitting without a jury, defendant, the government, and the judge all must agree that
the trial be conducted by the judge without a jury.

il. If the trial is a jury trial, the jury would be composed of
twelve citizens from the district, selected at random. Defendant and his attorney
would participate in choosing the jury by requesting that the Court remove
prospective jurors for cause where actual bias or other disqualification is shown, or
by removing prospective jurors without cause by exercising peremptory challenges.

iil. If the trial is a jury trial, the jury would be instructed that
defendant is presumed innocent, that the government has the burden of proving
defendant guilty beyond a reasonable doubt, and that the jury could not convict him
unless, after hearing all the evidence, it was persuaded of his guilt beyond a
reasonable doubt and that it was to consider each count of the information separately.
The jury would have to agree unanimously as to each count before it could return a
verdict of guilty or not guilty as to that count.

lv. If the trial is held by the judge without a jury, the judge
would find the facts and determine, after hearing all the evidence, and considering
each count separately, whether or not the judge was persuaded that the government
had established defendant’s guilt beyond a reasonable doubt.

Vv. At a trial, whether by a jury or a judge, the government

would be required to present its witnesses and other evidence against defendant.

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Defendant would be able to confront those government witnesses and his attorney
would be able to cross-examine them.

vi. At a trial, defendant could present witnesses and other
evidence in his own behalf. If the witnesses for defendant would not appear
voluntarily, he could require their attendance through the subpoena power of the
Court. A defendant is not required to present any evidence.

vil. At a trial, defendant would have a privilege against self-
incrimination so that he could decline to testify, and no inference of guilt could be
drawn from his refusal to testify. If defendant desired to do so, he could testify in his
own behalf.

vill. With respect to forfeiture, defendant understands that if
the case were tried before a jury, he would have a right to retain the jury to determine
whether the government had established the requisite nexus between defendant’s
offense and any specific property alleged to be subject to forfeiture.

d. Appellate and _ collateral rights. Defendant further
understands he is waiving all appellate issues that might have been available if he
had exercised his right to trial. Defendant is aware that Title 28, United States Code,
Section 1291, and Title 18, United States Code, Section 3742, afford a defendant the
right to appeal his conviction and the sentence imposed. Acknowledging this, if the
government makes a motion at sentencing for a downward departure pursuant to

Guideline § 5K1.1, defendant knowingly waives the right to appeal his conviction,

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any pre-trial rulings by the Court, and any part of the sentence (or the manner in
which that sentence was determined), including any term of imprisonment and fine
within the maximums provided by law, and including any order of restitution or
forfeiture, in exchange for the concessions made by the United States in this
Agreement. In addition, if the government makes a motion at sentencing for a
downward departure pursuant to Guideline § 5K1.1, defendant also waives his right
to challenge his conviction and sentence, and the manner in which the sentence was
determined, in any collateral attack or future challenge, including but not limited to
a motion brought under Title 28, United States Code, Section 2255. The waiver in
this paragraph does not apply to a claim of involuntariness or ineffective assistance
of counsel, nor does it prohibit defendant from seeking a reduction of sentence based
directly on a change in the law that is applicable to defendant and that, prior to the
filing of defendant’s request for relief, has been expressly made retroactive by an Act
of Congress, the Supreme Court, or the United States Sentencing Commission.

27. Defendant understands that, by pleading guilty, he is waiving all the
rights set forth in the prior paragraphs. Defendant’s attorney has explained those
rights to him, and the consequences of his waiver of those rights.

Presentence Investigation Report/Post-Sentence Supervision

28. Defendant understands that the United States Attorney’s Office in its
submission to the Probation Office as part of the Pre-Sentence Report and at

sentencing shall fully apprise the District Court and the Probation Office of the

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nature, scope, and extent of defendant’s conduct regarding the charges against him,
and related matters. The government will make known all matters in aggravation
and mitigation relevant to sentencing, including the nature and extent of defendant’s
cooperation.

29. Defendant agrees to truthfully and completely execute a Financial
Statement (with supporting documentation) prior to sentencing, to be provided to and
shared among the Court, the Probation Office, and the United States Attorney’s
Office regarding all details of his financial circumstances, including his recent income
tax returns as specified by the probation officer. Defendant understands that
providing false or incomplete information, or refusing to provide this information,
may be used as a basis for denial of a reduction for acceptance of responsibility
pursuant to Guideline § 3E1.1 and enhancement of his sentence for obstruction of
justice under Guideline § 3C1.1, and may be prosecuted as a violation of Title 18,
United States Code, Section 1001 or as a contempt of the Court.

30. For the purpose of monitoring defendant's compliance with his
obligations to pay a fine and restitution during any term of supervised release or
probation to which defendant is sentenced, defendant further consents to the
disclosure by the IRS to the Probation Office and the United States Attorney’s Office
of defendant's individual income tax returns (together with extensions,
correspondence, and other tax information) filed subsequent to defendant’s

sentencing, to and including the final year of any period of supervised release or

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Case: 1:25-cr-00132 Document #: 29 Filed: 06/30/25 Page 22 of 24 PagelD #:73

probation to which defendant is sentenced. Defendant also agrees that a certified copy
of this Agreement shall be sufficient evidence of defendant’s request to the IRS to
disclose the returns and return information, as provided for in Title 26, United States
Code, Section 6103(b).

Other Terms

31. Defendant agrees to cooperate with the United States Attorney’s Office
in collecting any ordered fine and restitution for which defendant is liable, including
providing financial statements and supporting records as requested by the United
States Attorney’s Office.

32. Defendant understands that, if convicted, a defendant who is not a
United States citizen may be removed from the United States, denied citizenship, and
denied admission to the United States in the future.

Conclusion

33. Defendant understands that this Agreement will be filed with the Court,
will become a matter of public record, and may be disclosed to any person.

34. Defendant understands that his compliance with each part of this
Agreement extends throughout the period of his sentence, and failure to abide by any
term of the Agreement is a violation of the Agreement. Defendant further
understands that in the event he violates this Agreement, the government, at its
option, may move to vacate the Agreement, rendering it null and void, and thereafter

prosecute defendant not subject to any of the limits set forth in this Agreement, or

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Case: 1:25-cr-00132 Document #: 29 Filed: 06/30/25 Page 23 of 24 PagelD #:74

may move to resentence defendant or require defendant’s specific performance of this
Agreement. Defendant understands and agrees that in the event that the Court
permits defendant to withdraw from this Agreement, or defendant breaches any of
its terms and the government elects to void the Agreement and prosecute defendant,
any prosecutions that are not time-barred by the applicable statute of limitations on
the date of the signing of this Agreement may be commenced against defendant in
accordance with this paragraph, notwithstanding the expiration of the statute of
limitations between the signing of this Agreement and the commencement of such
prosecutions.

35. Should the judge refuse to accept defendant’s plea of guilty, this
Agreement shall become null and void and neither party will be bound to it.

36. Defendant and his attorney acknowledge that no threats, promises, or
representations have been made, nor agreements reached, other than those set forth

in this Agreement, to cause defendant to plead guilty.

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Case: 1:25-cr-00132 Document #: 29 Filed: 06/30/25 Page 24 of 24 PagelD #:75

37. Defendant acknowledges that he has read this Agreement and carefully
reviewed each provision with his attorney. Defendant further acknowledges that he

understands and voluntarily accepts each and every term and condition of this

Agreement.
AGREED THIS DATE: > UNE 37, Zo
MICH ELLE Digitally signed by MICHELLE
ANDREW 8S. BOUTROS BARREN CARVYLE SADLER
United States Attorney Defendant
KARTIK K. RAMAN J EFFREY4&. LICHTMAN
Assistant U.S. Attorney Attorney for Defendant

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