Exhibit B: Statement of Cassie Will Darnall (Case 5:24-cr-00292-PCP, Document 84-2)

Summary

Exhibit B, Document 84-2 in Case 5:24-cr-00292-PCP, filed August 27, 2025, contains a written statement to the court by Cassie Will Darnall, letters from Sandra Will, Esther Moomjian and Kari Oliver, and a page headed Defense Mitigation Photos. In the statement, Cassie Will Darnall says that in 2019 she managed Rosswood Properties, that a contract was worth approximately $6 million, and that the loan against her home totaled about $900,000. She writes that she made "the grave mistake of applying for a PPP loan and falsifying documents", accepts full responsibility, and has drafted a repayment plan. Sandra Will writes that Cassie Will is her daughter and only child; Esther Moomjian writes that she has been Cassie's best friend for 30 years.

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Case 5:24-cr-00292-PCP   Document 84-2   Filed 08/27/25   Page 1 of 11




             Exhibit B
Case 5:24-cr-00292-PCP            Document 84-2         Filed 08/27/25     Page 2 of 11




Statement of Cassie Will Darnall

Your Honor,

My name is Cassie Will Darnall. I am 53 years old, born and raised in San Jose,
California. I hold advanced degrees from San Diego State University and Santa Clara
University. Since 2022, I have taught in the Union School District. I am also the
mother of an 11-year-old son,           , and the sole caregiver for my 86-year-old
mother. Both rely on me for care and stability.

In 2019, while completing my MBA, I managed Rosswood Properties, which
provided serviced housing for technology companies. That year, we secured a 200-
unit contract with Apple worth approximately $6 million. To meet the demands of
that contract, I made significant investments, leveraging my home to cover leases,
deposits, and furnishings. The loan against my home totaled about $900,000.

When the COVID-19 pandemic struck, the contract collapsed almost overnight. I
ultimately lost the home my father had passed down to me, and with it, a piece of my
family history. I was terrified of losing my current home as well, and of failing both
my son and my mother. Under that pressure, I made the grave mistake of applying for
a PPP loan and falsifying documents. I accept full responsibility for that decision. It
was not a calculated scheme, but an act of fear and desperation.

Throughout my life, I have valued honesty and integrity. For over 20 years, I have
volunteered with local pet shelters, churches, and schools, supporting those in need.
My professional record has been spotless, and I have often been recognized for my
reliability and commitment. That history makes my actions here all the more shameful
and out of character. I will live with this regret for the rest of my life.

At the time, I turned to alcohol to cope with stress and fear, which impaired my
judgment and contributed to my poor decision-making. Still, I truly believed I would
repay the loan in full, even if it took a lifetime. In business school, I had been taught
about using leverage and “other people’s money” as strategies for survival. Through
that misguided lens, borrowing dishonestly seemed like a way to keep everything
afloat.

I did not realize the full weight of my actions until it was too late.

My business, finances, and career are gone, yet I remain grateful to be employed
today as a Behavior Specialist with the Center for Social Dynamics–Autism Services.

Beyond my mistakes, I am a mother and daughter with serious responsibilities. My
son, who has obsessive-compulsive disorder, depends on me for stability. I devote at
least 15 hours a week coordinating his schooling and therapy. His other parent
struggles with mental health challenges, which makes my role even more essential.
My elderly mother also depends on me daily for meals, financial management, and
medication oversight. Without my support, both would be left vulnerable.

Your Honor, I am not seeking to avoid consequences. I accept responsibility and am
committed to restitution. I only ask that you consider the extraordinary circumstances
Case 5:24-cr-00292-PCP         Document 84-2        Filed 08/27/25     Page 3 of 11




that led to this mistake, the people who depend on me, and the steps I have taken to
rebuild my life. I now attend weekly therapy sessions—both individually and with my
son—to strengthen our coping and decision-making skills. I have also drafted a
repayment plan and intend to pay back these debts along with any fines imposed.

I am dedicated to making this right and ensuring it never happens again.

Respectfully,
Cassie Will Darnall
    Case 5:24-cr-00292-PCP   Document 84-2   Filed 08/27/25   Page 4 of 11




Honorable Judge:

My name is Sandra Will. Cassie Will is my daughter and only child. I am
wri ng because she has a sentencing hearing in your court soon.
I am a re red school teacher and administrator and Cassie’s Dad was an
instructor at Foothill Community College un l he re red. Cassie’s Dad
passed away in 2005 and le just the two of us. In 2012 Cassie adopted
a baby boy, Nick, (what a blessing) and enriched our lives.
Cassie a ended West Valley Community College, then went on to San
Diego State and Santa Clara University for her Master’s degree.
Cassie and her spouse were divorced in 2018. It was a difficult and
expensive divorce as many o en are.
When her business failed and covid became a worldwide condi on,
everything changed for everyone.
I don’t know anything about the PPP process but I do remember it was
adver sed on TV constantly.
I am 86 years old and Cassie is my only living blood rela ve except for a
few nephews and nieces who live on the east coast. Cassie is my whole
life now. She helps me stay well both physically and mentally and, she
has a great sense of humor and humility and love that enriches my life
every day. I will be lost and alone without her.
 She is a wonderful mother and her son adores and admires her and at
his age, she is the world to him. She takes him to every a er school
ac vity, every li le league game, basketball, football, soccer, etc. and to
the baseball spring training camp in Arizona every year. Her backyard is
a small baseball camp for him and his friends.
She recently had a difficult surgery and the experience of her illness was
very hard on me and Nick. He was shaken and afraid and he stays close
to her now.

Thank you,

Sandra Will
Case 5:24-cr-00292-PCP       Document 84-2      Filed 08/27/25    Page 5 of 11




Dear Honorable Judge:

My name is Esther Moomjian, and I have had the privilege of being Cassie’s
best friend for 30 years. In that time, she has become more than just a
friend—she is my chosen sister.

Her son is like my own nephew, andI have watched him grow up. I’ve watched
Cassie raise him with patience, love, and unshakable devotion. He is a
sensitive, bright, and loving child who absolutely needs his mother.

Without her, he would be lost. The emotional toll of separation would be
devastating for him—especially considering the mental health challenges he
already navigates. The reality is, I believe this could have a long-term
traumatic impact on him. I mean, he wouldn’t just be losing his mom. He’d be
losing his safe place, his anchor.

Cassie has a huge, generous and compassionate heart. She’s one of those
rare people who shows up for everyone, no matter what she’s going through
herself. She is also very entertaining and has many friends.

I’ve seen her lend her last dollar to someone in need, and I’ve watched her sit
quietly with strangers just to make sure they don’t feel alone in a hard moment.
That’s who Cassie is. She lives with empathy, and she gives with her whole
heart.

What happened after COVID was heartbreaking. After many years of hard
work, Cassie had finally built something incredible—her business, Rosswood
Properties, was thriving. After years of dedication, grit, and sacrifice, she
landed a life-changing contract. She invested everything she had—her time,
her money, her childhood home—to make it work. And then, like so many
others, the pandemic ripped it all away.

I remember those months. She tried so hard to hold it all together. She didn’t
tell anyone the full extent of how bad things had gotten, because that’s how
she is—proud, strong, and never wanting to be a burden. She truly believed,
based on what the government and media were saying, that things would turn
around quickly. That she could keep her home and pay back the loans within
a few months.

What she did was an act of desperation. She didn’t do it out of greed or with
bad intent. She was trying to keep a roof over her son’s head. She thought
she could fix it. And I know she would have—if things had gone even a little
differently.

I know Cassie feels horrible about the decision she made. I have sat with her
and witnessed her regret. But, I also believe that she made the decision she
did at the time with no ill intent.
Case 5:24-cr-00292-PCP       Document 84-2      Filed 08/27/25    Page 6 of 11




I know she carries that guilt every single day. But she is also committed—truly
committed—to making it right. She’s ready to repay everything she owes, and
more than that, she wants to help others as part of her retribution. That’s what
sets her apart: even now, even in this moment of deep regret, she is still
thinking about how she can serve and uplift others.

I would also like to share that Cassie’s ex-wife is a very challenging person. I
have seen firsthand how emotionally taxing and unstable that dynamic can be.
Leaving Cassie’s son in her care for any extended time would be not only
mentally detrimental for him—but potentially traumatizing. His emotional well-
being depends on the stability and nurturing that only Cassie provides.

Please, I am asking you from the depths of my heart: give Cassie the chance
to make amends without being taken away from the people who need her
most. She is not a danger to society—she is a human who made a desperate
mistake in a moment of crisis. Her heart, her intentions, and her character are
good and true. I know she will make this right.

Sincerely,




ECM
Cassie’s Best Friend & Devoted “Auntie” to 1111 and adopted animals; Kody
and Tiger.
     Case 5:24-cr-00292-PCP        Document 84-2      Filed 08/27/25    Page 7 of 11




Kari Oliver




 Dear Honorable Judge,

I am writing to provide a character reference for Cassie Will Darnell, whom I have
known for six years. I understand that Cassie is appearing before you in court, and I
would like to express my support for her.

I met Cassie on the first day of Kindergarten for both of our sons. It was an emotional
time for both of us- my last child was starting school, and it was Cassie's first. Our
shared experience immediately connected us. Cassie's intentionality with her son,
     ' stood out to me most. She radiated excitement and pride as she watched him
•
                                                                         II
     ark on this new journey. Over the past six years, Cassie has become one of my
closest friends and confidantes. Her greatest accomplishment is being
She dedicates herself fully to making memories and striving to be the oes mom she
                                                                                    mother.

can be. My children know her as "Aunt Cassie," and she treats them as if they were her
own. She has made a significant impact on my family's lives. • is also very
emotionally connected and bonded to her. He still prefers to o activities and events
with her present as he does not like to be without her. The separation of Cassie from
      would be devastating and life-altering for •   . I tru ly believe it would change the
• J ctory of his life. She is his number one suppo system and safe place in life.

I am aware of the charges that Cassie is facing, and I know that she has taken full
responsibility for her actions. Cassie has expressed to me her remorse and regret for
her decisions. I also own a small business, and during the pandemic, Cassie and I
shared our struggles in trying to stay afloat. I understood the difficulties she was
dealing with and how stressful and desperate she felt at the time. The pandemic was a
frightening and uncertain period, and Cassie made decisions that she believed were
necessary for her survival. I genuinely believe that she is a person of good character
who made a mistake and is committed to making amends. She has become someone I
can count on and rely upon. I have come to know her as a person of integrity, honesty,
and strong moral character.


Cassie has lived her life to the fullest, continuously striving to be a positive member of
society. She is an avid volunteer at her son 's school, dedicating countless hours to
ensure he has the best learning environment possible. She is actively involved in all of
her son 's sporting events, leaving a positive impact wherever she goes. Cassie
frequently hosts playdates for her son and his friends, organizing group outings,
baseball games, kickball games in her yard, neighborhood tag, swim parties at the
     Case 5:24-cr-00292-PCP      Document 84-2      Filed 08/27/25   Page 8 of 11




local pool, and much more. She is an active member of her community and is often
sought out for advice and support in neighborhood events. Cassie enhances the lives
of those around her just by being herself. I believe Cassie feels profound remorse for
her actions. I also believe that she did what she thought was necessary to survive at
the time without fully understanding the severity of her actions. I am confident she will
continue to be the best mother she can be, a positive member of society, and will make
valuable contributions to her community.

Thank you for considering my letter. I am available to answer any questions or provide
further information if needed.

Sincerely,

Kari Oliver
Case 5:24-cr-00292-PCP   Document 84-2         Filed 08/27/25   Page 9 of 11


                    United States v. Cassie Will-Darnall
                            CR 24-00292-PCP
                        Defense Mitigation Photos
Case 5:24-cr-00292-PCP   Document 84-2   Filed 08/27/25   Page 10 of 11
Case 5:24-cr-00292-PCP   Document 84-2   Filed 08/27/25   Page 11 of 11


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