Indictment — United States v. Guillermo Lopez Carrazana et al., Southern District of Florida (Document 3)
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A grand jury Indictment in United States of America v. Guillermo Lopez Carrazana, Christian Mendoza, and Max Alberto Mera Ulloa, Case No. 25-CR-20178-ALTMAN/LETT, in the U.S. District Court for the Southern District of Florida, entered on the docket April 18, 2025 as Document 3. Count 1 charges conspiracy to commit wire fraud under 18 U.S.C. § 1349 from in or around May 2020 through on or about March 2021, and Counts 2-10 charge wire fraud under 18 U.S.C. § 1343. It alleges that the defendants submitted approximately 165 false PPP loan applications, with falsified IRS forms and bank records, for their own companies and for other borrowers in return for kickbacks. It alleges that Lenders 1 through 4 disbursed over $6,500,000 in loan proceeds, and it seeks forfeiture under 18 U.S.C. § 982(a)(2)(A).
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“Indictment — United States v. Guillermo Lopez Carrazana et al., Southern District of Florida (Document 3).”
Original at ecf.flsd.uscourts.gov. Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/indictment-usa-v-ulloa-et-al-dkt-3-s-d-fla-b7aa990fa7/
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Case 1:25-cr-20178-EA Document 3 Entered on FLSD Docket 04/18/2025 Page 1 of 15
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
25-CR-20178-ALTMAN/LETT
Case No.
18 u.s.c. § 1349
18 u.s.c. § 1343
18 U.S.C. § 982(a)(2)(A)
UNITED STATES OF AMERICA
BM
vs.
GUILLERMO LOPEZ CARRAZANA,
Apr 17, 2025
CHRISTIAN MENDOZA, and
MAX ALBERTO MERA ULLOA, MIAMI
Defendants.
- - - - - - - - - - - - - - - -I
INDICTMENT
The Grand Jury charges that:
GENERAL ALLEGATIONS
At all times relevant to this Indictment:
The Small Business Administration
1. The United States Small Business Administration ("SBA") was an executive
branch agency of the United States government that provided support to entrepreneurs and small
businesses. The mission of the SBA was to maintain and strengthen the nation's economy by
enabling the establishment and viability of small businesses and by assisting in the economic
recovery of communities after disasters.
2. As part of this effort, the SBA enabled and provided for loans through banks, credit
unions, and other lenders. These loans had government-backed guarantees.
The Paycheck Protection Program
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3. The Coronavirus Aid, Relief, and Economic Security ("CARES") Act was a federal
law enacted in or around March 2020 and designed to provide emergency financial assistance to
the millions of business owners who were suffering the economic effects caused by the COVID-
19 pandemic. One source of relief provided by the CARES Act was the authorization of forgivable
loans to small businesses, including sole proprietorships, for job retention and certain other
expenses, through a program referred to as the Paycheck Protection Program ("PPP").
4. In order to obtain a PPP loan, a qualifying sole proprietorship submitted a PPP loan
application, which was signed by an authorized representative of the business. The PPP loan
application required the sole proprietorship (through its authorized representative) to acknowledge
the program rules and make certain affirmative certifications in order to be eligible to obtain the
PPP loan. In the PPP loan application (SBA Form 2483-C), the applicant (through its authorized
representative) was required to state, among other things, its: (a) average monthly payroll
expenses; and (b) number of employees. These figures were used to calculate the amount of money
the sole proprietorship was eligible to receive under the PPP. In addition, businesses applying for
a PPP loan were required to provide documentation confirming their payroll expenses.
5. A PPP loan application was processed by a participating lender. If a PPP loan
application was approved, the participating lender funded the PPP loan using its own monies.
While it was the participating lender that issued the PPP loan, the loan was 100% guaranteed by
the SBA. Data from the application, including information about the borrower, the total amount
of the loan and the listed number of employees, was transmitted by the lender to the SBA in the
course of processing the loan.
6. PPP loan proceeds were required to be used by the business on certain permissible
expenses- payroll costs, interest on mortgages, rent, and utilities. The PPP allowed the interest
2
Case 1:25-cr-20178-EA Document 3 Entered on FLSD Docket 04/18/2025 Page 3 of 15
and principal on the PPP loan to be entirely forgiven if the business spent the loan proceeds on
these expense items within a designated period of time and used a defined portion of the PPP loan
proceeds on payroll costs.
7. In 2021 , "Second Draw" PPP loans became available to PPP applicants who used
the full loan amount of their PPP funds on eligible expenses.
The Defendants, Defendant Businesses, and Lenders
8. Lender 1 was a lender based in New York, and was an approved SBA lender of
PPP Loans.
9. Lender 2 was a lender based in Georgia, and was an approved SBA lender of PPP
loans.
10. Lender 3 was a lender based in Utah, and was an approved SBA lender of PPP
loans.
11. Lender 4 was a lender based in New Jersey, and was an approved SBA lender of
PPP loans.
12. G LUX LLC was a Florida Corporation that listed its principal place of business in
Miami, Florida.
13 . Global Tax and Accounting Group Corp. ("Global Tax") was a Florida Corporation
that listed its principal place of business in Miami, Florida.
14. CM Logistic Systems LLC ("CM Logistics") was a Florida Corporation that listed
its principal place of business in Miami , Florida.
15 . Max Mera Corporation was a Florida Corporation that listed its principal place of
business in Aventura, Florida.
3
Case 1:25-cr-20178-EA Document 3 Entered on FLSD Docket 04/18/2025 Page 4 of 15
16. GUILLERMO LOPEZ CARRAZANA was a resident of Miami-Dade County
and owner ofG LUX LLC.
17. CHRISTIAN MENDOZA was a resident of Miami-Dade County and owner of
Global Tax and CM Logistics.
18. MAX ALBERTO MERA ULLOA was a resident of Miami-Dade County and
controlled Max Mera Corporation.
19. Co-conspirator 1, a resident of Miami-Dade County, Florida, was a borrower of a
PPP loan.
20. Co-conspirator 2, a resident of Miami-Dade County, Florida, was a borrower of a
PPP loan.
21. Co-conspirator 3, a resident of Broward County, Florida, was a borrower of a PPP
loan.
22. Co-conspirator 4, a resident of Miami-Dade County Florida, was a borrower of a
PPP loan.
COUNT 1
Conspiracy to Commit Wire Fraud
(18 u.s.c. § 1349)
1. Paragraphs 1 through 22 of the General Allegations Section of this Indictment are
re-alleged and incorporated by reference as though fully set forth herein.
2. From in or around May 2020, and continuing through on or about March 2021 , in
Miami-Dade and Broward Counties, in the Southern District of Florida, and elsewhere, the
defendants.
4
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GUILLERMO LOPEZ CARRAZANA,
CHRISTIAN MENDOZA, and
MAX ALBERTO MERA ULLOA,
did willfully, that is, with the intent to fu1iher the object of the conspiracy, and knowingly combine,
conspire, confederate, and agree with each other, co-conspirators 1-4, and others known and
unknown to the Grand Jury, to knowingly, and with the intent to defraud, devise, and intend to
devise, a scheme and artifice to defraud, and to obtain money and property by means of materially
false and fraudulent pretenses, representations, and promises, knowing that the pretenses,
representations, and promises were false and fraudulent when made, and, for the purpose of
executing the scheme and artifice, did knowingly transmit and cause to be transmitted, by means
of wire communications in interstate and foreign commerce, certain writings, signs, signals,
pictures, and sounds, in violation of Title 18, United States Code, Section 1343 .
PURPOSE OF THE CONSPIRACY
3. It was the purpose of the conspiracy for the defendants and their co-conspirators to
unjustly enrich themselves by, among other things: (a) submitting and causing the submission of
false and fraudulent applications for loans made available through the SBA to provide relief for
the economic effects caused by the COVID-19 pandemic, including PPP loans; (b) offering,
paying, and receiving kickbacks in return for referring other individuals, such as co-conspirators
1-4, for the submission of false and fraudulent loan applications; and (c) diverting fraud proceeds
for the defendants' and co-conspirators' personal use, the use and benefit of others, and to further
the conspiracy.
5
Case 1:25-cr-20178-EA Document 3 Entered on FLSD Docket 04/18/2025 Page 6 of 15
MANNER AND MEANS OF THE CONSPIRACY
The manner and means by which the defendants and their co-conspi rators sought to
accomplish the obj ect and purpose of the conspiracy included, among others, the fo llowing:
4. Beginning sometime in May 2020, GUILLERMO LOPEZ CARRAZANA,
CHRISTIAN MENDOZA, and MAX ALBERTO MERA ULLOA submitted, and caused the
submi ss ion of, fa lse and fraudul ent PPP loan applications, on behalf of themselves and corporate
entities that they contro lled, such as G LUX LLC, Global Tax, CM Logistics, and Max Mera
Corporati on. LOPEZ CARRAZANA, MENDOZA, and MERA ULLOA, in return for the
payment of kickbacks, also submitted and caused the submi ss ion of false and fraudulent PPP loan
appl icati ons for other borrowers, including co-conspi rators 1-4. In some instances, LOPEZ
CARRAZANA and MENDOZA submitted and caused the submiss ion of both first draw and
second draw PPP loan applicati ons on behalf of themselves and co-conspirators.
5. In furth erance of the scheme, GUILLERMO LOPEZ CARRAZANA,
CHRISTIAN MENDOZA, and MAX ALBERTO MERA ULLOA subm itted, and caused the
submiss ion of, fa lse and fraudul ent info rm ati on and documentati on in support of PPP loan
applicati ons, including fa lsified Internal Revenue Service ("IRS") forms, fa lse and fra udu lent bank
records, and other documents, that falsely and fraudulently represented the monthly payro ll and
the number of employees fo r the co rporate entities they controlled.
6. In fmih erance of the scheme, GUILLERMO LOPEZ CARRAZANA,
CHRISTIAN MENDOZA, and MAX ALBERTO MERA ULLOA submitted, and caused the
submi ss ion of, approximately 165 fa lse and fra udulent PPP loan applications fo r their corporations
and other borrowers' corporations, that totaled nearl y $2 1,000,000 .
6
Case 1:25-cr-20178-EA Document 3 Entered on FLSD Docket 04/18/2025 Page 7 of 15
7. As a result of the false and fraudulent PPP loan applications submitted as part of
this scheme, Lenders 1 through 4 approved PPP loans to entities belonging to the defendants and
their co-conspirators and disbursed, via interstate wire transmission, over $6,500,000 in loan
proceeds into bank accounts controlled by the defendants ' and their co-conspirators.
8. GUILLERMO LOPEZ CARRAZANA, CHRISTIAN MENDOZA, and MAX
ALBERTO MERA ULLOA, and their co-conspirators, including co-conspirators l-4, used the
proceeds from the scheme to enrich themselves and others, and to further the scheme.
All in violation of Title 18, United States Code, Section 1349.
COUNTS 2-10
Wire Fraud
(18 u.s.c. § 1343)
1. Paragraphs 1 through 22 of the General Allegations Section of this Indictment are
re-alleged and incorporated by reference as though fully set forth herein.
2. On or about the dates specified below, in Miami Dade and Broward Counties, in
the Southern District of Florida, and elsewhere, the defendant(s), as indicated below, did
knowingly, and with the intent to defraud, devise, and intend to devise, a scheme and artifice to
defraud, and to obtain money and property by means of materially false and fraudulent pretenses,
representations, and promises, knowing that the pretenses, representations, and promises were
false and fraudulent when made, and, for the purpose of executing the scheme and artifice, did
knowingly transmit and cause to be transmitted, by means of wire communication in interstate
commerce, certain writings, signs, signals, pictures, and sounds, in violation of Title 18, United
States Code, Section 134 3.
7
Case 1:25-cr-20178-EA Document 3 Entered on FLSD Docket 04/18/2025 Page 8 of 15
PURPOSE OF THE SCHEME AND ARTIFICE
3. It was the purpose of the scheme and artifice for the defendants and their
accomplices to unjustly enrich themselves by, among other things: (a) submitting and causing the
submission of false and fraudulent applications for loans and made available through the SBA to
provide relief for the economic effects caused by the COVID-19 pandemic, including PPP loans;
(b) offering, paying, and receiving kickbacks in return for referring other individuals, such as co-
conspirators 1-4, for the submission of false and fraudulent loan applications; and (c) diverting
fraud proceeds for the defendants' and co-conspirators' personal use, the use and benefit of others,
and to further the scheme and artifice.
THE SCHEME AND ARTIFICE
4. The allegations contained in paragraphs 4 through 8 of the Manner and Means
Section of Count 1 of this Indictment are re-alleged and incorporated by reference as though fully
set forth herein as a description of the scheme and artifice.
USE OF WIRES
5. On or about the dates below, in the Southern District of Florida, and elsewhere, the
defendant indicated below, for the purpose of executing and in furtherance of the aforesaid scheme
and artifice to defraud, and to obtain money and property by means of materially false and
fraudulent pretenses, representations, and promises, knowing that the pretenses, representations,
and promises were false and fraudulent when made, did knowingly transmit and cause to be
transmitted in interstate and foreign commerce, by means of wire communication, certain writings,
signs, signals, pictures, and sounds, as described below:
8
Case 1:25-cr-20178-EA Document 3 Entered on FLSD Docket 04/18/2025 Page 9 of 15
•
COUNT DEFENDANT(s) APPROXIMATE DESCRIPTIO OF WIRE
DATE
2 GUILLERMO LOPEZ May 11, 2020 Electronic transmission from the
CARRAZANA Southern District of Florida to
outside of the State of Florida of a
PPP loan application to Lender 1
that falsely and fraudulently
misrepresented the monthly
payroll amount and number of
employees ofG LUX LLC.
3 GUILLERMO LOPEZ May 29, 2020 Electronic Transmission from the
CARRAZANA and Southern District of Florida to
MAXALBERTO outside the State of Florida of a
MERA ULLOA PPP loan application to Lender 3
that falsely and fraudulently
misrepresented the monthly
payroll amount and number of
employees of a company owned
by co-conspirator 1.
4 GUILLERMO LOPEZ June 2, 2020 Electronic transmission from the
CARRAZANA and Southern District of Florida to
MAX ALBERTO outside of the State of Florida of a
MERA ULLOA PPP loan application to Lender 3
that falsely and fraudulently
misrepresented the monthly
payroll amount and number of
employees of Max Mera
Corporation.
s GUILLERMO LOPEZ June 15, 2020 Electronic transmission from the
CARRAZANA and Southern District of Florida to
CHRISTIAN outside of the State of Florida of a
MENDOZA PPP loan application to Lender 3
that falsely and fraudulently
misrepresented the monthly
payroll amount and number of
employees of Global Tax.
6 GUILLERMO LOPEZ June 28, 2020 Electronic Transmission from the
CARRAZANA and Southern District of Florida to
CHRISTIAN outside the State of Florida of a
MENDOZA PPP loan application to Lender 4
that falsely and fraudulently
misrepresented the monthly
payroll amount and number of
employees of a company owned
by co-conspirator 2.
9
Case 1:25-cr-20178-EA Document 3 Entered on FLSD Docket 04/18/2025 Page 10 of 15
COUNT DEFENDANT(s) APPROXIMATE DESCRIPTION OF WIRE
DATE
7 GUILLERMO LOPEZ July 16, 2020 Electronic transmission from the
CARRAZANA and Southern District of Florida to
CHRISTIAN outside of the State of Florida of a
MENDOZA PPP loan application to Lender 2
that falsely and fraudulently
misrepresented the monthly
payroll amount and number of
employees of CM Logistics.
8 GUILLERMO LOPEZ July 28, 2020 Electronic Transmission from the
CARRAZANA Southern District of Florida to
outside the State of Florida of a
PPP loan application to Lender 2
that falsely and fraudulently
misrepresented the monthly
payroll amount and number of
employees of a company owned
by co-conspirator 3.
9 GUILLERMO LOPEZ February 25, 2021 Electronic Transmission from the
CARRAZANA and Southern District of Florida to
MAXALBERTO outside the State of Florida of a
MERA ULLOA PPP loan application to Lender 4
that falsely and fraudulently
misrepresented the monthly
payroll amount and number of
employees of a company owned
by co-conspirator 4.
10 GUILLERMO LOPEZ March 16, 2021 Electronic transmission from the
CARRAZANA and Southern District of Florida to
CHRISTIAN outside of the State of Florida of a
MENDOZA PPP loan application to Lender 3
that falsely and fraudulently
misrepresented the monthly
payroll amount and number of
employees of Global Tax.
In violation of Title 18, United States Code, Sections 1343 and 2.
Case 1:25-cr-20178-EA Document 3 Entered on FLSD Docket 04/18/2025 Page 11 of 15
FORFEITURE ALLEGATIONS
1. The allegations contained in this Indictment are hereby re-alleged and by this
reference full y incorporated herein for the purpose of alleging forfeiture to the United States of
America of certain property in which the defendants, GUILLERMO LOPEZ CARRAZA A,
CHRISTIAN MENDOZA, and MAX ALBERTO MERA ULLOA, have an interest.
2. Upon conviction of a violation of Title 18, United States Code, Section 1343, or a
conspiracy to violate Section 1343, as alleged in this Indictment, the defendant shall forfeit to the
United States any property constituting, or derived from, proceeds obtained directly or indirectly,
as a result of such violation, pursuant to Title 18, United States Code, Section 982(a)(2)(A).
3. Upon conviction of a violation of Title 18, United States Code, Section 1343, or a
conspiracy to violate Section 1343, as alleged in this Indictment, the defendant shall forfeit to the
United States any property, real or personal, which constitutes or is derived from proceeds
traceable to such offense, pursuant to Title 18, United States Code, Section 981(a)(l )(C).
All pursuant to Title 18, United States Code, Sections 982(a)(2)(A) and 981(a)(l)(C) and
the procedures set forth at Title 21 , United States Code, Section 853 , as incorporated by Title 18,
United States Code, Section 982(b)(l) and Title 28, United States Code, Section 2461(c).
S D \'BY ~
UNITED STATES ATTORNEY
ROGER CRUZ
ASSISTANT UNITED STATES ATTORNEY
11
Case 1:25-cr-20178-EA Document 3 Entered on FLSD Docket 04/18/2025 Page 12 of 15
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
UNITED STATES OF AMERICA 25-CR-20178-ALTMAN/LETT
CASE NO.: - ----------------
v.
GUILLERMO LOPEZ CARRAZANA, CERTIFICATE OF TRIAL ATTORNEY
CHRJSTIAN MENDOZA, and
MAX ALBERTOMERA ULLOA
- - - - - - - - - - - - - - - - -I Superseding Case Information:
New Defendant(s) (Yes or No) _ _
Court Division (select one) Number of New Defendants - -
E]Miami □ Key West □ FTP Total number of new counts
OFTL OWPB
I do hereby certify that:
1. I have carefull y considered the al legations of the Indi ctment, the number of defendants, the number of probable
witnesses and the legal complexities of the Indi ctment/Information attached hereto.
2. I am aware that the information supplied on this statement wi ll be rel ied upon by the Judges of this Court in setting
their calendars and scheduling crim inal trials under the mandate of the Speedy Trial Act, 28 U.S.C. §316 I.
3. Interpreter: (Yes or N o ) ~
List language and/or dialect:_S..._pa_n_i_sh_ _ _ __
4. This case will take 14 days for the parties to try.
5. Please check appropriate category and type of offense li sted be low:
(Check only one) (Check onl y one)
I D Oto 5 days □ Petty
II D 6 to 10 days □ Minor
III D 11 to 20 days D Misdemeanor
IV D 21 to 60 days El Fe lony
V D 61 days and over
6. Has this case been previously filed in this District Court? (Yes or No)No
--
Ifyes, Judge _ _ _ _ _ _ _ _ _ _ _ Case No. _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ __
7. Has a complaint been filed in this matter? (Yes or No) No
--
lfyes, Judge _ _ _ _ _ _ _ _ _ _ _ Magistrate Case No. _ _ _ _ _ _ _ _ _ _ _ _ __
8. Does this case relate to a previously filed matter in this District Court? (Yes or No)N_o_
If yes, Judge _ _ _ _ _ _ _ _ _ _ _ Case No ._ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ __
9. Defendant(s) in federa l custody as of _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ __
10. Defendant(s) in state custody as of _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ __
11 . Rule 20 from the _ _ _ _ _ District of _ _ _ _ _ __
12 . ls this a potential death penalty case? (Yes orNo)_N_o_
13. Does th is case originate from a matter pending in the Central Region of the U.S. Attorney ' s Office
prior to October 3, 20 19 (Mag. Judge Jared M. Strauss)? (Yes orNo) :tiQ__
14. Did this matter involve the participation of or cons ultatio n with Magistrate Judge Eduardo I. Sanchez
during his tenure at the U.S . Atto rney ' s Office, which conc luded on January 22, 2023? _N _o_
15. Did this matter involve the participation of or consu ltation with Magistrate Judge Marty Fulgueira
Elfenbein during her tenure at the U.S. Attorney ' s Office, which conc luded on March 5, 2024? _0_
16. Did th is matter invo lve the participation of or consultation with Magistrate Judge Ellen F. D ' Angelo
during her tenure at the U.S . Attorney' s Office, wh ich conc luded on October 7, 2024? :riQ__
By fw>A ?Yr~:
Roger Cr z
Ass istant United States Attorney
FL Bar o.1579 17
Case 1:25-cr-20178-EA Document 3 Entered on FLSD Docket 04/18/2025 Page 13 of 15
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
PENALTY SHEET
Defendant's Name: GUILLERMO LOPEZ CARRAZANA
Case No : - - -- - -- -- - - -- - - - - -- -- - - - - - - -- - - -
Count #1:
Conspiracy to Commit Wire Fraud
Title 18, United States Section Code, Section 1349
*Max.Term oflmprisonment: Twenty (20) Years
* Mandatory Min. Term oflmprisonment (if applicable): N/A
* Max. Supervised Release: Three (3) years
* Max. Fine: $250,000 or twice the gross gain or gross loss
Counts #2-1 0:
Wire Fraud
Title 18, United States Section Code, Section 1343
*Max.Term oflmprisonment: Twenty (20) years
* Mandatory Min. Term oflmprisonment (if applicable): N/A
* Max. Supervised Release: Three (3) Years
* Max. Fine: $250,000 or twice the gross gain or gross loss
*Refers on ly to possible term of incarceratio n, supe rvised rel ease and fines. It do es not include
restitu tion, special assessments, {Jarole tenn s, or forfeitu res that may be applicable.
Case 1:25-cr-20178-EA Document 3 Entered on FLSD Docket 04/18/2025 Page 14 of 15
UNITED STA TES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
PENAL TY SHEET
Defendant's ame: CHRISTIAN MENDOZA
Case No: - - -- -- -- - -- - - -- - - -- -- -- - - -- - - -- -
Count # 1:
Conspiracy to Commit Wire Fraud
Title 18, United States Section Code, Section 1349
*Max.Term oflmprisonment: Twenty (20) Years
* Mandatory Min. Term of Imprisonment (if applicable): N/ A
* Max. Supervised Release: Three (3) years
* Max. Fine: $250,000 or twice the gross gain or gross loss
Counts #5, 6, 7, and 10:
Wire Fraud
Title 18, United States Section Code, Section 1343
* Max. Term of Imprisonment: Twenty (20) years
* Mandatory Min. Term oflmprisonment (if applicable): N/A
* Max. Supervised Release: Three (3) Years
* Max. Fine: $250,000 or twice the gross gain or gross loss
*Refers only to possib le term of incarceration, sup ervised release and fin es. It does not includ e
restitution , spec ia l assessments, parole terms, or foi·feitures th at may be applicable.
Case 1:25-cr-20178-EA Document 3 Entered on FLSD Docket 04/18/2025 Page 15 of 15
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
PENAL TY SHEET
Defendant's Name: MAX ALBERTO MERA ULLOA
Case No: - -- - - -- -- - -- - -- - - -- - -- -- - -- - - -- -
Count #1:
Conspiracy to Commit Wire Fraud
Title 18, United States Section Code, Section 1349
* Max. Term oflmprisonment: Twenty (20) Years
* Mandatory Min. Term oflmprisonment (if applicable): NIA
* Max. Supervised Release: Three (3) years
* Max. Fine: $250,000 or twice the gross gain or gross loss
Counts #3, 4, and 9
Wire Fraud
Title 18, United States Section Code, Section 1343
* Max. Term of Imprisonment: Twenty (20) years
* Mandatory Min. Term oflmprisonment (if applicable): NIA
* Max. Supervised Release: Three (3) Years
* Max. Fine: $250,000 or twice the gross gain or gross loss
*Refe rs on ly to possible term of in carceration, supervised r·elease a nd fines. It d oes not includ e
r esti tution , special assess ments, parole terms, or forfeitures that may be app li ca bl e.
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