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Memorandum of Interview, Sheri Darnall — SBA Office of Inspector General, 5:24-cr-00292-PCP (Document 119-1)

Summary

Exhibit packet filed 01/07/26 as Document 119-1 in United States v. Cassie Will-Darnall, Case 5:24-cr-00292-PCP, U.S. District Court for the Northern District of California, concerning her request to extend her 01/12/2026 self-surrender date. It opens with an SBA Office of Inspector General Memorandum of Interview of Sheri Darnall, conducted December 31, 2025 by Special Agent Angel Huling and an FBI agent at the request of an Assistant United States Attorney, in which she disputes statements in the defendant's pro se Motion to Extend Self-Surrender Date. The motion says the primary caregiver for the defendant's mother left on December 9, 2025, and declarations are dated 12/12/2025. The packet also contains a Judgment imposing 18 months for bank fraud and wire fraud and a December 2, 2025 travel order.

Summary drafted by a model from the document's text below and checked by script against that text before publication. It is a navigation aid, not a reading of what the document proves. Where AI is used

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“Memorandum of Interview, Sheri Darnall — SBA Office of Inspector General, 5:24-cr-00292-PCP (Document 119-1).” Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/gov-uscourts-cand-430212-119-1-c9691b2831/, SHA-256 aec5c8281ce84d18378e8ea28d02afc395447d88099e6047b7d050738383d7aa.

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Case 5:24-cr-00292-PCP Document119-1 Filed 01/07/26 Page 2 of 28

U.S. SMALL BUSINESS ADMINISTRATION
OFFICE OF INSPECTOR GENERAL
INVESTIGATIONS DIVISION

Prepared by: SA ANGEL HULING
Approved by: ASAC JONATHAN HUANG

MEMORANDUM OF INTERVIEW

CASE#: 2023-0024346 CASE AGENT: SA ANGEL HULING
CASE TITLE: WILL-DARNALL, CASSIE

INVESTIGATIVE ASSISTANCE: IA RACQUEL ALVARADO

DATE: January 5, 2025

On December 31, 2025, the reporting agent (RA), Angel Huling, Special Agent (SA), U.S. Small
Business Administration (SBA), Office of Inspector General (OIG), and SA Kenneth Kuhns,
Federal Bureau of Investigation (FBI) conducted a telephonic interview of Sheri Darnall (Sheri).
This interview was not recorded.

SAs identified themselves to Sheri verbally and advised the purpose of the interview was to discuss
a Motion to Extend Self-Surrender Date (“Subject Document”), Cassie Will-Darnall (Cassie)
provided to the court on December 29, 2025 (Attachment 1). (Agent’s Note: The RA contacted
Sheri at the request of Sarah Griswold, Assistant United States Attorney.)

Sheri said she saw the Subject Document in Cassie’s criminal case file on PACER (Public Access
To Court Electronic Records) on December 30, 2025. In the Subject Document, Cassie is asking
the court to grant a 60-day extension of her self-surrender date, scheduled for January 12, 2025.
Sheri believes Cassie is requesting an extension so she can take their son on vacation. Sheri said
Cassie recently told their son she wanted to go to Spring Training in Arizona in March. Sheri
stated the claims Cassie made in the Subject Document are not truthful.

In the Subject Document, Cassie stated, “defendant has fully complied with all conditions of
release”. Sheri reported she knows Cassie has been drinking alcohol. (Agent’s Note: When Cassie
was sentenced on September 24, 2025, one of the Special Conditions of Supervision listed in the
Judgment [Attachment 2] stated, “You must abstain from the use of all alcoholic beverages.”)

Sheri recalled receiving a telephone call from Cassie on October 4, 2025. Sheri said Cassie told
her their son had gotten upset because he saw Cassie drinking a Margarita at the County Fair and
Cassie had driven them home. Sheri said Cassie and their son eventually returned to the County
Fair, where Sheri saw Cassie drink two (2) glasses of white wine, while playing Bingo. Sheri said
she ended up driving their son home, because she didn’t want him to get in the car with Cassie,
who had been drinking.

Page | of 2
RESTRICTED This report is confidential and may contain information that is prohibited from disclosure by the Privacy Act,
INFORMATION 5 USC 552a. Therefore, this report is furnished solely on an official need-to-know basis and must not be
released or disseminated to any other party without prior written consent of the Assistant Inspector General
SBA FORM 21 for Investigations of the Small Business Administration/or designee. Unauthorized release may result in
09/18 criminal prosecution and/or other penalties as may be available under law.
Case 5:24-cr-00292-PCP Document119-1 Filed 01/07/26 Page 3 of 28

Sheri said she recently saw Cassie drinking in a photograph on Facebook posted by a mutual friend
(Attachment 3). According to Sheri, the photograph was posted on Christmas Eve. Sheri said
there were three (3) women in the photograph, whom she identified as Cassie, Tricia Fornesi, and
Majken Bullard. Sheri believes the photograph was taken in a bar and Cassie is drinking a martini.
(Agent’s Note: The RA reviewed the Facebook photograph provided by Sheri and observed a
female subject, who is similar in appearance to Cassie, holding a frosted martini glass containing
a clear liquid and a green olive.)

In the Subject Document, Cassie stated the reason she is requesting an extension of her surrender
date is because “the primary caregiver for Sandra Will unexpectedly and abruptly terminated her
employment” on December 9, 2025. According to Sheri, Sandra Will, (“Cassie’s mother’), does
not have a caregiver.

Sheri said Cassie’s mother lives alone and golfs several times a week. According to Sheri, Cassie’s
mother went to the driving range with their son within the past week. Sheri said Cassie’s mother
spoke at Cassie’s sentencing hearing without issue.

Sheri said she saw Cassie’s mother at Cassie’s house on Christmas Day, unloading gifts from her
vehicle without assistance and without any obvious mobility issues. Sheri spoke with Cassie’s
mother briefly and did not observe any cognitive issues.

In the Subject Document, Cassie stated her mother is “unable to safely manage her daily needs
independently”. Cassie also asserted she is “the sole individual providing necessary care and
supervision” for her mother. Sheri said Cassie left her mother at home alone for a week, from
December 17 to December 23, when she took their son on a ski trip to Breckenridge, CO. (Agent’s
Note: On December 2, 2025, in an Order Temporarily Modifying Conditions of Pretrial Release,
[Attachment 4], the court granted Cassie permission to travel.)

Sheri said Esther Moomjian (Esther), a longtime family friend, who had been renting a room from
Cassie’s mother, moved out in December. Sheri said Esther was now living in Cassie’s rental unit,
which is attached to Cassie’s residence located at 111 Bellwood Gateway, Los Gatos, CA.
(Agent’s Note: As part of her sentence, Cassie was ordered to forfeit her interest in the property
at 111 Bellwood Gateway.)

Attachments:
1. Motion to Extend Self-Surrender Date, received December 29, 2025
2. Judgment in a Criminal Case, signed October 1, 2025
3. Copy of photograph posted on Facebook
4. Order Temporarily Modifying Conditions of Pretrial Release, signed December 2, 2025

Page 2 of 2
RESTRICTED This report is confidential and may contain information that is prohibited from disclosure by the Privacy Act,
INFORMATION 5 USC 552a. Therefore, this report is furnished solely on an official need-to-know basis and must not be
released or disseminated to any other party without prior written consent of the Assistant Inspector General
SBA FORM 21 for Investigations of the Small Business Administration/or designee. Unauthorized release may result in
09/18 criminal prosecution and/or other penalties as may be available under law.
SCANNED “SS

DEC 29 2025

CLERK, U.S. DISTRICT C:
NORTH DISTRICT OF CALIFORNIA

IN THE UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF CALIFORNIA

UNITED STATES OF AMERICA ( CASENO. _ 5:24-cr-00292-PEAPL{OSE OFFICE
(
PLAINTIFF (JUDGE P. CASEY PITTS
(
-V- (MOTION TO EXTEND
(_ SELF-SURRENDER DATE
CASSIE WILL-DARNALL (
(
DEFENDANT (

Now comes the Defendant, Cassie Will-Darnall, or pro se, and respectfully moves this
Honorable Court for an Order extending the Defendant’s self-surrender date to the custody of the
Bureau of Prisons. In support thereof, Defendant states as follows:

1. Procedural Background

The Court sentenced Defendant to a term of imprisonment of 18 months, and ordered
Defendant to self-surrender to the Bureau of Prisons on 01/12/2026.

Defendant has fully complied with all conditions of release and has appeared as ordered
throughout these proceedings.
2. Legal Authority

This Court retains authority to modify the date and manner of execution of its sentence.
The 9th Circuit held that “[i]f the circumstances warrant, a district court may delay the
imposition of sentence or extend the time to surrender to the BOP.”See United States v. United

States v. Fower No. 21-50007, 2022 (9th Circuit, April 4, 2022), see also 18 U.S.C. § 3143(a).
3. Good Cause Exists for an Extension

Good cause exists for a brief extension of the surrender date due to the following
circumstances:

The primary caregiver for Sandra Will unexpectedly and abruptly terminated her
employment, leaving Ms. Will without any in-home assistance or support. As a result, Sandra
Will is currently without a caregiver and is unable to safely manage her daily needs
independently. At present, Cassie Will-Darnall is the sole individual providing necessary care
and supervision

Ms. Will-Darnall requires additional time to secure, vet, and properly train a replacement
caregiver to ensure continuity of care and avoid placing her mother at risk. An extension of the
surrender date is respectfully requested to allow Ms. Will-Darnall to stabilize her mother’s
caregiving situation before incarceration.

Absent a brief extension, Ms. Will-Darnall’s immediate surrender would leave Sandra
Will without essential care, placing her health and safety at substantial risk. This request is
narrowly tailored and made in good faith, and is consistent with the factors set forth in 18 U.S.C.
§ 3553(a), including the history and characteristics of the defendant and the need to avoid
unnecessary hardship to a vulnerable dependent, while preserving the integrity of the Court’s
sentence and ensuring Ms. Will-Darnall’s timely and orderly surrender once appropriate care is
in place.

Defendant is not seeking to delay execution of sentence indefinitely, but only a reasonable 60
day extension to ensure orderly compliance with the Court’s judgment. Defendant poses no risk

of flight or danger to the community and will surrender as ordered by the Court.
4. Requested Relief

Defendant respectfully requests that the Court extend the self-surrender date from 01/12/2026 to

time 60 days from your report date, or such other date as the Court deems just and appropriate.
WHEREFORE, Defendant, Cassie Will-Darnall respectfully prays that this Court grant

the Motion and extend the Defendant’s self-surrender date an additional sixty 60 days.

Respectfully Submitted,

Cassie Will-Darnall

111 Belwood Gateway Los Gatos
CA 95032

(408) 596-1511

Lggirll6@yahoo.com
Pro Se
This packet demonstrates the following:

1. My mother medically requires a caregiver.

2. She does not currently have one.

3. I am proactively searching for one through licensed agencies
and private caregivers.

4. She needs daily assistance for safety, technology, and
legal/medical tasks.

5. This documentation reflects legitimate, good-faith efforts to
secure proper care.

Respectfully submitted,
Cassie Will Darnall
Caregiver Need & Active Search Evidence Packet

1. Functional Needs Assessment Summary

Completed by Former Caregiver Agency :

This functional assessment reflects the typical findings from a
licensed Home Health Agency or Geriatric Care Manager:

ADLs she needs assistance with:
¢ Dressing

¢ Bathing

¢ Supervision for safety

¢ Medication reminders

IADLs she needs assistance with:

¢ Technology use (email, online systems, documents)
¢ Managing legal paperwork

¢ Scheduling and understanding appointments

¢ Financial or complex decision making
Recommendation:
Client requires daily support and a consistent caregiver to ensure
safety and proper handling of legal/medical matters.

3. Incident Log (Starting October 2025)

¢ 10/03/2025 — Difficulty understanding voicemail from attorney;
needed step-by-step explanation.

¢ 10/08/2025 — Became confused while paying a bill online; unable
to navigate website without full guidance.

¢ 10/14/2025 — Misplaced important legal documents; later found
them in the kitchen with food items.

¢ 10/19/2025 — Forgot how to use television remote; unable to
change input or find news channel.

* 10/23/2025 — Repeatedly asked the same question about lawsuit
deadlines within one hour.

¢ 10/27/2025 — Attempted to call attorney but dialed random
contacts instead; became frustrated and upset.

¢ 10/30/2025 — Mistook scam email for official court notice;
required intervention to prevent response.

¢ 11/01/2025 — Forgot scheduled medical appointment despite
reminders; needed escort and re-explanation.

° 11/03/2025 — Confused by text message from Medicare; believed
benefits were being cut.

¢ 11/07/2025 — Unable to locate medications; required help
organizing daily pillbox.

° 11/09/2025 — Became anxious after misinterpreting a routine
notice from insurance as a termination letter.

¢ 11/13/2025 — Could not recall passwords for banking; locked
herself out of online account.

° 11/16/2025 — Forgot whether she ate breakfast; attempted to take
medication twice.
¢ 11/19/2025 — Needed help understanding a court date reminder
letter; believed it was a demand notice.

¢ 11/22/2025 — Confused when attempting to print documents;
printer jam escalated her anxiety.

* 11/25/2025 — Misidentified phone scam caller as a government
agency; nearly shared personal information.

¢ 11/28/2025 — Forgot how to check voicemail; required full
guidance and emotional reassurance.

¢ 11/30/2025 — Could not understand difference between attorney
retainer letter and invoice; became distressed.

¢ 12/03/2025 — Forgot to attend scheduled lab appointment;
appointment had to be rescheduled and transportation arranged.
¢ 12/07/2025 — Became confused by prescription refill notice;
believed medication had been discontinued.

e 12/11/2025 — Could not turn on the microwave; required
supervision to ensure safety.
Section B — Evidence that She Has No Current Caregiver
DECLARATION OF CASSIE WILL DARNALL

I, Cassie Will Darnall, declare under penalty of perjury:

1. My mother, Sandra Will, does not currently have a caregiver.
Her caregiver left Dec 9th 2025.

2. She is not receiving any in-home support services.

3. There is no caregiver under contract, no agency providing care,
and she receives no daily care aside from my assistance.

4, Due to her needs, I am the only person helping her manage
technology, legal tasks, and daily responsibilities.

5. ] am actively seeking a caregiver on her behalf and have
contacted multiple agencies.

I declare under penalty of perjury that the foregoing is true and
correct.

Date: 12/12/2025
DECLARATION OF SANDRA WILL

I, SANDRA WILL, declare that I do not have a caregiver at this
time. No agency or individual is providing daily assistance to me.
Cassie is reaching out to agencies and referrals to find a helper for
me.

I understand that my daughter is helping me search for an
appropriate caregiver, and currently is my caregiver.

Date: 12/12/2025
Signature:
Case 5:24-cr-00292-PCP Document119-1 Filed 01/07/26 Page 16 of 28

AO 245B (Rev. AO 09/19-CAN 12/19) Judgment in Criminal Case

UNITED STATES DISTRICT COURT
Northern District of California

UNITED STATES OF AMERICA JUDGMENT IN A CRIMINAL CASE

Vv.
Cassie Will-Darnall USDC Case Number: CR-24-00292-001 PCP
BOP Case Number: DCAN524CRO00292-001
USM Number: 18002-511

Defendant’s Attorney: Varell Laphalle Fuller (AFPD)

THE DEFENDANT:
[¥ pleaded guilty to counts: One and two of the Information.

f— pleaded nolo contendere to count(s): which was accepted by the court.

[~ was found guilty on count(s): after a plea of not guilty.

The defendant is adjudicated guilty of these offenses:

Title & Section Nature of Offense Offense Ended Count
18 U.S.C. § 1344(2) Bank Fraud March 2021 1
18 U.S.C. § 1343 Wire Fraud March 2021 2

The defendant is sentenced as provided in pages 2 through _8_ of this judgment. The sentence is imposed pursuant to the Sentencing
Reform Act of 1984.

[— The defendant has been found not guilty on count(s):
f— Count(s) dismissed on the motion of the United States.

It is ordered that the defendant must notify the United States attorney for this district within 30 days of any change of name, residence,
or mailing address until all fines, restitution, costs, and special assessments imposed by this judgment are fully paid. If ordered to pay
restitution, the defendant must notify the court and United States attorney of material changes in economic circumstances.

9/24/2025

Date of Imposition of _—

Signature @ Judge

The Honorable P. Casey Pitts
United States District Judge
Name & Title of Judge

10/1/2025
Date
Case 5:24-cr-00292-PCP Document119-1 Filed 01/07/26 Page 17 of 28

AO 245B (Rev. AO 09/19-CAN 12/19) Judgment in Criminal Case

DEFENDANT: Cassie Will-Darnall Judgment - Page 2 of 8
CASE NUMBER: CR-24-00292-001 PCP

IMPRISONMENT

The defendant is hereby committed to the custody of the United States Bureau of Prisons to be imprisoned for a total term of:

18 months. This term consists of terms of 18 months as to Counts One and Two, all counts to be served concurrently.

The appearance bond is hereby exonerated, or upon surrender of the defendant as noted below. Any cash bail plus interest shall be
returned to the owner(s) listed on the Affidavit of Owner of Bond Security form on file in the Clerk's Office.

Iv

-

The Court makes the following recommendations to the Bureau of Prisons:
The Court recommends that the defendant participate in the Bureau of Prisons Residential Drug Abuse Treatment Program.
The defendant is remanded to the custody of the United States Marshal.

The defendant shall surrender to the United States Marshal for this district:
iz at on (no later than 2:00 pm).

as notified by the United States Marshal.

The defendant shall surrender for service of sentence at the institution designated by the Bureau of Prisons:

Iv on 1/7/2026 (no later than 2:00 pm).
as notified by the United States Marshal.

f~ as notified by the Probation or Pretrial Services Office.

RETURN

I have executed this judgment as follows:

Defendant delivered on to at

, with a certified copy of this judgment.

UNITED STATES MARSHAL

By

DEPUTY UNITED STATES MARSHAL
Case 5:24-cr-00292-PCP Document119-1 Filed 01/07/26 Page 18 of 28

AO 245B (Rev. AO 09/19-CAN 12/19) Judgment in Criminal Case

DEFENDANT: Cassie Will-Darnall Judgment - Page 3 of 8
CASE NUMBER: CR-24-00292-001 PCP

SUPERVISED RELEASE

Upon release from imprisonment, the defendant shall be on supervised release for a term of: Three years. This term consists of terms
of three years on each of Counts One and Two, all such terms to run concurrently.

2)
3)

4)

5)
6)

7)

MANDATORY CONDITIONS OF SUPERVISION

You must not commit another federal, state or local crime.

You must not unlawfully possess a controlled substance.

You must refrain from any unlawful use of a controlled substance. You must submit to one drug test within 15 days of release
from imprisonment and at least two periodic drug tests thereafter, as determined by the court.

Iv

“14

-

\¥ The above drug testing condition is suspended, based on the court's determination that you pose a low risk of
future substance abuse. (check if applicable)
You must make restitution in accordance with 18 U.S.C. §§ 3663 and 3663A or any other statute authorizing a sentence
of restitution. (check if applicable)

You must cooperate in the collection of DNA as directed by the probation officer. (check if applicable)
You must comply with the requirements of the Sex Offender Registration and Notification Act (34 U.S.C. § 20901, et
seq.) as directed by the probation officer, the Bureau of Prisons, or any state sex offender registration agency in which

you reside, work, are a student, or were convicted of a qualifying offense. (check if applicable)
You must participate in an approved program for domestic violence. (check if applicable)

You must comply with the standard conditions that have been adopted by this court as well as with any other conditions on the
attached page.
Case 5:24-cr-00292-PCP Document119-1 Filed 01/07/26 Page 19 of 28

AO 245B (Rev. AO 09/19-CAN 12/19) Judgment in Criminal Case

DEFENDANT: Cassie Will-Darnall Judgment - Page 4 of 8
CASE NUMBER: CR-24-00292-001 PCP

STANDARD CONDITIONS OF SUPERVISION

As part of your supervised release, you must comply with the following standard conditions of supervision. These conditions are
imposed because they establish the basic expectations for your behavior while on supervision and identify the minimum tools needed
by probation officers to keep informed, report to the court, and bring about improvements in your conduct and condition.

1) You must report to the probation office in the federal judicial district where you are authorized to reside within 72 hours of
RELEASE, unless the probation officer instructs you to report to a different probation office or within a different time frame.

2) After initially reporting to the probation office, you will receive instructions from the court or the probation officer about how
and when you must report to the probation officer, and you must report to the probation officer as instructed.

3) You must not knowingly leave the federal judicial district where you are authorized to reside without first getting permission
from the court or the probation officer.

4) You must follow the instructions of the probation officer related to the conditions of supervision.

5) You must answer truthfully the questions asked by your probation officer.

6) You must live at a place approved by the probation officer. If you plan to change where you live or anything about your

living arrangements (such as the people you live with, for example), you must notify the probation officer at least 10 days
before the change. If notifying the probation officer in advance is not possible due to unanticipated circumstances, you must
notify the probation officer within 72 hours of becoming aware of a change or expected change.

7) You must allow the probation officer to visit you at any time at your home or elsewhere, and you must permit the probation
officer to take any items prohibited by these and the special conditions of your supervision that he or she observes in plain
view.

8) You must work at least part-time (defined as 20 hours per week) at a lawful type of employment unless excused from doing

so by the probation officer for schooling, training, community service or other acceptable activities. If you plan to change
where you work or anything about your work (such as your position or your job responsibilities), you must notify the
probation officer at least 10 days before the change. If notifying the probation officer at least 10 days in advance is not
possible due to unanticipated circumstances, you must notify the probation officer within 72 hours of becoming aware of a
change or expected change.

9) You must not communicate or interact with someone you know is engaged in criminal activity.

10) If you are arrested or questioned by a law enforcement officer, you must notify the probation officer within 72 hours.

11) You must not act or make any agreement with a law enforcement agency to act as a confidential human source or informant
without first getting the permission of the court.

12) You must not own, possess, or have access to a firearm, ammunition, destructive device, or dangerous weapon (i.e., anything

that was designed, or was modified for, the specific purpose of causing bodily injury or death to another person such as
nunchakus or tasers).

Iv If the probation officer determines that you pose a risk to a third party, the probation officer may require you to notify the
person about the risk and you must comply with that instruction. The probation officer may contact the person and confirm
that you have notified the person about the risk. (check if applicable)

U.S. Probation Office Use Only

A USS. probation officer has instructed me on the conditions specified by the court and has provided me with a written copy of this
judgment containing these conditions. I understand that the court may (1) revoke supervision, (2) extend the term of supervision,
and/or (3) modify the conditions of supervision upon a finding of a violation of probation or supervised release.

(Signed)

Defendant Date

US. Probation Officer/Designated Witness Date

SPECIAL CONDITIONS OF SUPERVISION
Case 5:24-cr-00292-PCP Document119-1 Filed 01/07/26 Page 20 of 28

AO 245B (Rev. AO 09/19-CAN 12/19) Judgment in Criminal Case

DEFENDANT: Cassie Will-Darnall Judgment - Page 5 of 8
CASE NUMBER: CR-24-00292-001 PCP

1. You must not open any new lines of credit and/or incur new debt without the prior permission of the
probation officer.

2. You must provide the probation officer with access to any financial information, including tax returns,
and must authorize the probation officer to conduct credit checks and obtain copies of income tax
returns.

3. You must submit your person, residence, office, vehicle, or any property under your control, including

any computers, cell phones, and other electronic devices, to a search. Such a search must be conducted
by a United States Probation Officer at a reasonable time and in a reasonable manner, based upon
reasonable suspicion of contraband or evidence of a violation of a condition of release. Failure to submit
to such a search may be grounds for revocation. You must warn any residents that the premises may
be subject to searches.

4. You must abstain from the use of all alcoholic beverages.
Case 5:24-cr-00292-PCP Document119-1 Filed 01/07/26 Page 21 of 28

AO 245B (Rev. AO 09/19-CAN 12/19) Judgment in Criminal Case

DEFENDANT: Cassie Will-Darnall

Judgment - Page 6 of 8
CASE NUMBER: CR-24-00292-001 PCP

CRIMINAL MONETARY PENALTIES

The defendant must pay the total criminal monetary penalties under the schedule of payments.

Assessment Fine Restitution AVAA JVTA
Assessment* Assessment**
TOTALS $200.00 Waived To Be Determined N/A N/A

[4 The determination of restitution is deferred until December 13, 2025. An Amended Judgment in a Criminal Case (AO 245C)
will be entered after such determination.

[~ The defendant must make restitution (including community restitution) to the following payees in the amount listed below.

If the defendant makes a partial payment, each payee shall receive an approximately proportioned payment, unless specified
otherwise in the priority order or percentage payment column below. However, pursuant to 18 U.S.C. § 3664(i), all
nonfederal victims must be paid before the United States is paid.

Name of Payee Total Loss** Restitution Ordered Priority or Percentage

TOTALS $ 0.00 $ 0.00

[~ Restitution amount ordered pursuant to plea agreement $

[~ The defendant must pay interest on restitution and a fine of more than $2,500, unless the restitution or fine is paid in full

before the fifteenth day after the date of the judgment, pursuant to 18 U.S.C. § 3612(f). All of the payment options on Sheet 6
may be subject to penalties for delinquency and default, pursuant to 18 U.S.C. § 3612(g).
[— The court determined that the defendant does not have the ability to pay interest and it is ordered that:

[— the interest requirement is waived for the.

[~ the interest requirement is waived for the is modified as follows:

* Amy, Vicky, and Andy Child Pornography Victim Assistance Act of 2018, Pub. L. No. 115-299.
** Justice for Victims of Trafficking Act of 2015, Pub. L. No. 114-22.

*** Findings for the total amount of losses are required under Chapters 109A, 110, 110A, and 113A of Title 18 for offenses committed on or after September 13, 1994,
but before April 23, 1996.
Case 5:24-cr-00292-PCP Document119-1 Filed 01/07/26 Page 22 of 28

AO 245B (Rev. AO 09/19-CAN 12/19) Judgment in Criminal Case

DEFENDANT: Cassie Will-Darnall Judgment - Page 7 of 8
CASE NUMBER: CR-24-00292-001 PCP

SCHEDULE OF PAYMENTS

Having assessed the defendant’s ability to pay, payment of the total criminal monetary penalties is due as follows’:

A [~ Lump sum payment of due immediately, balance due

not later than , or
[~ in accordance with [Cc fF Dior Ff Eand/or l~ F below); or

B_ [Payment to begin immediately (may be combined with [~ CG [ D,or | Fbelow); or

C f[ Payment in equal (e.g., weekly, monthly, quarterly) installments of _ over a period of (e.g., months or years), to
commence (e.g., 30 or 60 days) after the date of this judgment; or

D [Payment in equal (e.g., weekly, monthly, quarterly) installments of _ over a period of (e.g., months or years), to
commence (e.g., 30 or 60 days) after release from imprisonment to a term of supervision; or

E [~ Payment during the term of supervised release will commence within (e.g., 30 or 60 days) after release from
imprisonment. The court will set the payment plan based on an assessment of the defendant’s ability to pay at that time; or

F Special instructions regarding the payment of criminal monetary penalties:
It is further ordered that the defendant shall pay to the United States a special assessment of $200.00 and restitution
to the Small Business Administration in an amount to be determined by the Court. During imprisonment, payment
of criminal monetary penalties are due at the rate of not less than $25 per quarter and payment shall be through
the Bureau of Prisons Inmate Financial Responsibility Program. Once the defendant is on supervised release,
restitution must be paid in monthly payments of not less than $150.00 or at least 10 percent of earnings, whichever
is greater, to commence no later than 60 days from placement on supervision. Notwithstanding any payment
schedule set by the court, the United States Attorney’s Office may pursue collection through all available means in
accordance with 18 U.S.C. §§ 3613 and 3664(m). Payments shall be made to the Clerk of U.S. District Court,
Attention: Financial Unit, 450 Golden Gate Ave., Box 36060, San Francisco, CA 94102, or via the pay.gov online
payment system.

Unless the court has expressly ordered otherwise, if this judgment imposes imprisonment, payment of criminal monetary penalties is
due during imprisonment. All criminal monetary penalties, except those payments made through the Federal Bureau of Prisons’

Inmate Financial Responsibility Program, are made to the clerk of the court.

The defendant shall receive credit for all payments previously made toward any criminal monetary penalties imposed.

| Joint and Several

Case Number Total Amount Joint and Several Corresponding Payee,
Defendant and Co-Defendant Names Amount if appropriate
(including defendant number)

[~ The defendant shall pay the cost of prosecution.

[~ The defendant shall pay the following court cost(s):

*“ Payments shall be applied in the following order: (1) assessment, (2) restitution principal, (3) restitution interest, (4) AVAA assessment,
(5) fine principal, (6) fine interest, (7) community restitution, (8) JVTA assessment, (9) penalties, and (10) costs, including cost of
prosecution and court costs.
Case 5:24-cr-00292-PCP Document119-1 Filed 01/07/26 Page 23 of 28

AO 245B (Rev. AO 09/19-CAN 12/19) Judgment in Criminal Case

DEFENDANT: Cassie Will-Darnall Judgment - Page 8 of 8
CASE NUMBER: CR-24-00292-001 PCP

Iv

The defendant shall forfeit the defendant’s interest in the following property to the United States:

¢ Real Property located at 111 Belwood Gateway, Los Gatos CA 95032, Santa Clara County, APN 527-31-019;

¢ All funds in an amount to be determined by the Court on deposit in a Vanguard account ending in -6846, held in the name of
Alternative Health Services Inc., and all interest accrued since seizure of those funds; and

¢ A forfeiture money judgment to be determined in the future.

The Court gives notice that this case involves other defendants who may be held jointly and severally liable for payment of all

or part of the restitution ordered herein and may order such payment in the future, but such future orders do not affect the
defendant’s responsibility for the full amount of the restitution ordered.
Case 5:24-cr-00292-PCP Document119-1 Filed 01/07/26 Page 24 of 28

ATTACHMENT 3
Case 5:24-cr-00292-PCP Document119-1 Filed 01/07/26 Page 26 of 28

ATTACHMENT 4
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JODI H. LINKER

Federal Public Defender
VARELL L. FULLER

Assistant Federal Public Defender
55 S. Market Street, Suite 820
San Jose, CA 95113

Telephone: (408) 291-7753
Varell_Fuller@fd.org

Counsel for Defendant WILL-DARNALL

UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF CALIFORNIA

SAN JOSE DIVISION

UNITED STATES OF AMERICA, No. 24-CR-00292 PCP (VKD)

Plaintiff,
UNOPPOSED MOTION AND [PROPOSED]
Vv. ORDER TEMPORARILY MODIFYING
CONDITIONS OF PRETRIAL RELEASE
CASSIE WILL-DARNALL,

Defendant. Judge: Hon. Virginia K. DeMarchi

Defendant Cassie Will-Darnall, by and through counsel, respectfully requests that the
Court temporarily modify her pretrial release conditions to permit her to travel to Longview,
Colorado, for a ski trip from December 17 to 23, 2025. The purpose of Ms. Will-Darnall’s travel
is a personal vacation with her minor child. Counsel has conferred with Pretrial Services Officer
Yaneyla Arevalo-Arellano and Assistant United States Attorney Sarah Griswold, and neither

objects to this modification.

Motion to Temporarily Modify Conditions of Pretrial Release
WILL-DARNALL, 24-292 PCP
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Dated: December 2, 2025 JODI H. LINKER
FEDERAL PUBLIC DEFENDER

/s/
VARELL L. FULLER
Assistant Federal Public Defender

[PROPOSED] ORDER
GOOD CAUSE APPEARING, upon the defendant’s unopposed motion, IT IS HEREBY
ORDERED that the defendant’s pretrial release conditions are temporarily modified to permit
the defendant to travel from San Jose to Longview, Colorado from December 17, 2025 to
December 23, 2025.
All other conditions are to remain in full effect.

IT IS SO ORDERED.

THE H®NORABLE VIR‘ IA K. DEMARCHI
United States Magistrate Judge

DATED: December 2, 2025

Motion to Temporarily Modify Conditions of Pretrial Release
WILL-DARNALL, 24-292 PCP


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