Statement of Facts — United States v. Donal Lesesne, No. 1:24-cr-00018 (Northern District of Florida)

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A Statement of Facts filed October 16, 2024 as Document 27 in United States v. Donal Lesesne, Case No. 1:24-cr-00018-AW-MAL, in the U.S. District Court for the Northern District of Florida, Gainesville Division. The United States states that it provides the factual basis for acceptance of the guilty plea of Defendant Donal Lesesne. It states that on or about August 2, 2021 the Defendant created an account with the California Employment Development Department (CA EDD) and that the application contained material false statements, including that the Defendant had worked in California. It states that the Defendant received $18,604 in CA EDD UI funds. It closes with the elements of the offense for Count One.

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Case 1:24-cr-00018-AW-MAL Document27_ Filed 10/16/24 Page1of3

IN THE UNITED STATES DISTRICT COURT FOR THE
NORTHERN DISTRICT OF FLORIDA
GAINESVILLE DIVISION
UNITED STATES OF AMERICA
Vv. Case No: 1:24cr18-AW-MAL

DONAL LESESNE
/

STATEMENT OF FACTS

THE UNITED STATES OF AMERICA, by and through the undersigned
Assistant United States Attorney, provides this factual basis for the acceptance of
the guilty plea of Defendant Donal Lesesne (“Defendant”). Should this case proceed
to trial, the government is prepared to present evidence as follows:

In or around March 2020, the Coronavirus Aid, Relief, and Economic
Security (CARES) Act was enacted. It was designed to provide emergency
financial assistance to the millions of Americans who were suffering from the
economic effects caused by the COVID-19 pandemic. During the period of time
including April of 2021, the California Employment Development Department
(“CA EDD”) Unemployment Insurance program was funded in part by the federal
CARES Act.

On or about August 2, 2021, the Defendant created and caused the creation

of an account with the CA EDD. As part of the application process, the Defendant

Filed jn Open Court
Clerk “US. District Court
Northern District of Florida
underwent verification by a third party company, ID.me, which was designed to
verify the identity of applicants. As part of that application, the Defendant
participated in live video verification with an employee of ID.me, during which he
affirmed that he was attempting to verify for “California unemployment.” The
Defendant also provided a date of birth and his social security number. Following
verification, the Defendant caused to be submitted an application in support of
unemployment insurance benefits through the CA EDD. The submission of the
Defendant’s unemployment insurance application was completed via the internet,
and as such the submission of this application constituted a wire communication
transmitted in interstate commerce.

The Defendant’s CA EDD unemployment insurance application contained
material false statements, including representations that the Defendant had worked
in California and was forced to stop working due to the COVID-19 pandemic. In
reality, and as the Defendant knew, the Defendant has never lived or worked in the
state of California, and was not entitled to unemployment insurance benefits from
the CA EDD. Through the false statements contained in his application, the

Defendant received $18,604 in CA EDD UI funds to which he was not entitled.
Case 1:24-cr-00018-AW-MAL Document27_ Filed 10/16/24 Page3of3

ELEMENTS OF THE OFFENSE-COUNT ONE

(1)the Defendant knowingly devised or participated in a scheme to defraud, or
to obtain money or property by using false pretenses, representations, or
promises;

(2)the false pretenses, representations, or promises were about a material fact;

(3)the Defendant acted with the intent to defraud; and

(4) the Defendant transmitted or caused to be transmitted by wire some
communication in interstate commerce to help carry out the scheme to
defraud.

JASON R. COODY
United States Attorney

DARREN JOHNSON, ESQ. DAVID P. BYRON

Attorney for Defendant Florida Bar No. 0105777
Assistant United States Attorney

tip. inn Gg ly Northern District of Florida
PO/LG [AOA 401 SE First Ave, Ste 211
Date Gainesville, Florida 32601

(352) 378-0996

Defendant Date


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