United States v. Shamiese Wright — Plea Agreement Letter, Southern District of West Virginia (July 9, 2025)

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A plea agreement letter dated July 9, 2025 from the United States Attorney for the Southern District of West Virginia to Michelle R. Fox, counsel for Shamiese Wright, in United States v. Shamiese Wright, Criminal No. 2:24-cr-00192-2, filed July 14, 2025 as Document 319. Wright agrees to plead guilty to Count Two of a second superseding indictment, aiding and abetting laundering of monetary instruments under 18 U.S.C. §§ 1956(a) (1) (B) (i) and 2, and the United States will move to dismiss Count One. The letter lists a maximum penalty of 20 years and a fine of $500,000, restitution of up to $18,736.73, and a forfeiture money judgment of $12,625.00 that Wright agrees not to contest. In the attached Stipulation of Facts, Wright states she received a $15,625 PPP loan on or about May 7, 2021 and sent $3,000 of it by CashApp with misleading transfer descriptions.

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United States Department of Justice

United States Attorney
Southern District of West Virginia

Robert C. Byrd United States Courthouse 1-800-659-8726
300 Virginia Street, East 304-345-2200
Suite 4000 FAX: 304-347-5104

Charleston, WV 25301

July 9, 2025 } FILED

Michelle R. Fox, Esquire JUL | 4 2025
Law Offices of Michelle Roman Fox

3359 Teays Valley Road "RORY PERRY CLERK"
Hurricane, West Virginia 25526 Southem District of West Viphia

Re: United States v. Shamiese Wright
Criminal No. 2:24-cr-00192-2 (USDC SDWV)

Dear Ms. Fox:

This will confirm our conversations with regard to your
client, Shamiese Wright (hereinafter “Ms. Wright”). As a result
of these conversations, it is agreed by and between the United
States and Ms. Wright as follows:

i PENDING CHARGES. Ms. Wright is charged in a two-count
second superseding indictment as follows:

(a) Count One charges Ms. Wright with a violation of 18
U.S.C. §§ 1344 and 2 (aiding and abetting bank fraud) ;
and

(b) Count Two charges Ms. Wright with a violation of 18
U.S.C. §§ 1956(a) (1) (B) (i) and 2 (aiding and abetting
taundering of monetary instruments) .

Bis RESOLUTION OF CHARGES. Ms. Wright will plead guilty to
Count Two of said second superseding indictment, which charges her
with a violation of 18 U.S.C. §§ 1956(a) (1) (B) (i) and 2. Following

final disposition, the United States will move the Court to dismiss
Count One in Criminal No. 2:24-cr-00192-2 as to Ms. Wright.

reve

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Case 2:24-cr-00192 Document319 Filed 07/14/25 Page 2 of 12 PagelD #: 1782

Michelle R. Fox, Esquire
July 9, 2025 Re: Shamiese Wright

Page 2

3. MAXIMUM POTENTIAL PENALTY. The maximum penalty to which
Ms. Wright will be exposed by virtue of this guilty plea is as
follows:

(a) Imprisonment for a period of 20 years;

(b) A fine of $500,000, or twice the gross pecuniary gain or
twice the gross pecuniary loss resulting from
defendant’s conduct, whichever is greater;

(c) A term of supervised release of 3 years;

(d) A mandatory special assessment of $100 pursuant to 18
U.S.C. § 3013; and

(e) An order of restitution pursuant to 18 U.S.C. §§ 3663
and 3664, or as otherwise set forth in this plea
agreement.

4, SPECIAL ASSESSMENT. Prior to the entry of a plea pursuant
to this plea agreement, Ms. Wright will tender a check or money
order to the Clerk of the United States District Court for $100,
which check or money order shall indicate on its face the name of
defendant and the case number. The sum received by the Clerk will
be applied toward the special assessment imposed by the Court at
sentencing. Ms.,Wright will obtain a receipt of payment from the
Clerk and will tender a copy of such receipt to the United States,
to be filed with the Court as an attachment to this plea agreement.
If Ms. Wright fails to provide proof of payment of the special
assessment prior to or at the plea proceeding, the United States
will have the right to void this plea agreement. In the event
this plea agreement becomes void after payment of the special
assessment, such sum shall be promptly returned to Ms. Wright.

5. RESTITUTION. Notwithstanding the offense of conviction,
Ms. Wright agrees that she owes restitution in the amount up to
$18,736.73 and agrees to pay such restitution, with interest as
allowed by law, to the fullest extent financially feasible. In

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Michelle R. Fox, Esquire
July 9, 2025 Re: Shamiese Wright

Page 3

aid of restitution, Ms. Wright further agrees as follows:

(a) Ms. Wright agrees to fully assist the United States in
identifying and locating any assets to be applied toward
restitution and to give signed, sworn statements and
testimony concerning assets upon request of the United
States.

(b) Ms. Wright will fully complete and execute, under oath,
a Financial Statement and a Release of Financial
Information on forms supplied by the United States and
will return these completed forms to counsel for the
United States within seven calendar days from the date
of the signing of this plea agreement.

(c) Ms. Wright agrees not to dispose of, transfer or
otherwise encumber any real or personal property which
she currently owns or in which she holds an interest.

(d) Ms. Wright agrees to fully cooperate with the United
States in the liquidation of assets to be applied towards
restitution, to execute any and all documents necessary
to transfer title of any assets available to satisfy
restitution, to release any and all right, title and
interest she may have in and to such property, and waives
her right to exemptions under the Federal Debt
Collection Procedures Act upon levy against and the sale
of any such property.

(e) Ms. Wright agrees not to appeal any order of the District
Court imposing restitution unless the amount of
restitution imposed exceeds the amount set forth in this
plea agreement. However, nothing in this provision is
intended to preclude the Court from ordering Ms. Wright
to pay a greater or lesser sum of restitution in
accordance with law.

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Michelle R. Fox, Esquire

July 9, 2025 Re: Shamiese Wright
Page 4
6. FORFEITURE. Ms. Wright hereby agrees as follows:

(a) To forfeit to the United States any and all property in
Ms. Wright’s possession or under her control which
constitutes proceeds of or was derived from proceeds of
‘the offense to which Ms. Wright is agreeing to plead
guilty, and is set forth in the second superseding
indictment, namely the violation of 18 U.S.C. §§
1956(a) (1) (B) (i) and 2. Ms. Wright further agrees that
she will not contest a forfeiture money judgment in the
amount of $12,625.00;

(ob) To assist the United States and its agents in identifying
all such property, regardless of its location and the
manner in which it is titled. Any such identified
property deemed forfeitable by the United States will
then be forfeited, pursuant to 18 U.S.C. §§ 981, 982 or
28 U.S.C. § 2461, in either an administrative or judicial

forfeiture action;

(c) To fully complete and execute, under oath, a Financial
Affidavit in a form supplied by the United States and to
return to counsel for the United States the completed
Affidavit within seven calendar days from the date of
signing this plea agreement;

(d) To provide sworn testimony and to execute any documents
deemed necessary by the United States to effectuate the
forfeiture and to transfer title to the said property to
the United States; and

(e) To waive any defenses to this criminal action, or to any.
related administrative or judicial forfeiture action,
based in whole or in part on the Excessive Fines Clause
of the Eighth Amendment to the Constitution, or the
holding or principles set forth in United States v.
Alexander, 509 U.S. 544 (1993); United States v.
Bajakajian, 524 U.S. 321 (1998); United States v.

Bw

Defendant’s
Michelle R. Fox, Esquire
July 9, 2025 Re: Shamiese Wright

Page 5

Austin, 509 U.S. 602 (1993); and their progeny.

7. PAYMENT OF MONETARY PENALTIES. Ms. Wright authorizes
the Financial Litigation Program in the United States Attorney’s
Office to obtain a credit report from any major credit reporting
agency prior to sentencing in order to assess her financial
condition for sentencing purposes. Ms. Wright agrees not to
object to the District Court ordering all monetary penalties
(including the special assessment, fine, court costs, and any
restitution that does not exceed the amount set forth in this plea
agreement) to be due and payable in full immediately and subject
to immediate enforcement by the United States. So long as the
monetary penalties are ordered to be due and payable in full
immediately, Ms. Wright further agrees not to object to the
District Court imposing any schedule of payments as merely a
minimum schedule of payments and not the only method, nor a
limitation on the methods, available to the United States to

enforce the judgment.

Ms. Wright authorizes the United States, through the
Financial Litigation Program, to submit any unpaid criminal
monetary penalty to the United States Treasury for offset in
accordance with the Treasury Offset Program, regardless of the
defendant’s payment status or history at that time.

In addition to any payment ordered by the Court, Ms. Wright
shall pay all monies received from any source other than earned
income, including but not limited to, lottery winnings, gambling
proceeds, judgments, inheritances, and tax refunds, toward the
court ordered restitution or fine.

Ms. Wright agrees that if she retains counsel or has appointed
counsel in response to the United States’ efforts to collect any
monetary penalty, she shall immediately notify the United States
Attorney’s Office, Attention: Financial Litigation Program, 300
Virginia Street E., Suite 4000, Charleston, West Virginia 25301,
in writing and shall instruct her attorney to notify FLP

immediately of her representation.

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Michelle R. Fox, Esquire

July 9, 2025 Re: Shamiese Wright
Page 6
8. COOPERATION. Ms. Wright will be forthright and truthful

with this office and other law enforcement agencies with regard to
all inquiries made pursuant to this agreement, and will give
signed, sworn statements and grand jury and trial testimony upon
request of the United States. In complying with this provision,
Ms. Wright may have counsel present except when appearing before
a grand jury.

05 USE IMMUNITY. Unless this agreement becomes void due
to a violation of any of its terms by Ms. Wright, and except as
expressly provided for in paragraph 11 below, nothing contained in
any statement or testimony provided by her pursuant to this
agreement, or any evidence developed therefrom, will be used
against her, directly or indirectly, in any further criminal
prosecutions or in determining the applicable guideline range
under the Federal Sentencing Guidelines.

10. LIMITATIONS ON IMMUNITY. Nothing contained in this
agreement restricts the use of information obtained by the United
States from an independent, legitimate source, separate and apart
from any information and testimony provided pursuant to this
agreement, in determining the applicable guideline range or in
prosecuting Ms. Wright for any violations of federal or state laws.
The United States reserves the right to prosecute Ms. Wright for
perjury or false statement if such a situation should occur
pursuant to this agreement.

11. STIPULATION OF FACTS AND WAIVER OF FED. R. EVID. 410.
The United States and Ms. Wright stipulate and agree that the facts
comprising the offense of conviction and relevant conduct include
the facts outlined in the “Stipulation of Facts,” a copy of which
is attached hereto as “Plea Agreement Exhibit A.”

Ms. Wright agrees that if she withdraws from this agreement,
or this agreement is voided as a result of a breach of its terms
by her, and she is subsequently tried for her conduct alleged in
the indictment, as more specifically described in the Stipulation
of Facts, the United States may use and introduce the Stipulation

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Michelle R. Fox, Esquire
July 9, 2025 Re: Shamiese Wright

Page 7

of Facts in the United States case-in-chief, in cross-examination
of Ms. Wright or of any of her witnesses, or in rebuttal of any
testimony introduced by her or on her behalf. Ms. Wright knowingly
and voluntarily waives, see United States v. Mezzanatto, 513 U.S.
196 (1995), any right she has pursuant to Fed. R. Evid. 410 that
would prohibit such use of the Stipulation of Facts. If the Court
does not accept the plea agreement through no fault of the
defendant, or the Court declares the agreement void due to a breach
of its terms by the United States, the Stipulation of Facts cannot
be used by the United States.

The United States and Ms. Wright understand and acknowledge
that the Court is not bound by the Stipulation of Facts and that
if some or all of the Stipulation of Facts is not accepted by the
Court, the parties will not have the right to withdraw from the

plea agreement.

12. WAIVER OF APPEAL AND COLLATERAL ATTACK. Ms. Wright
knowingly and voluntarily waives her right to seek appellate review
of her conviction and of any sentence imposed by the District
Court, including any term of imprisonment, fine, term or condition
of supervised release, term or condition of probation, or special
assessment, or the manner in which the sentence was determined, on
any ground whatsoever including any ground set forth in 18 U.S.C.
§ 3742(a), except that the defendant may appeal any sentence that
exceeds the maximum penalty prescribed by statute. Ms. Wright also
knowingly and voluntarily waives any right to seek appellate review
of any claim or argument that (1) the statute of conviction, 18
U.S.C. §§ 1956(a) (1) (B) (i) and 2, is unconstitutional, and (2) Ms.
Wright conduct set forth in the Stipulation of Facts (Plea
Agreement Exhibit A) does not fall within the scope of 18 U.S.C.
§§ 1956(a) (1) (B) (i) and 2.

The United States also agrees to waive its right to appeal
any sentence imposed by the District Court, or the manner in which
the sentence was determined, on any ground whatsoever, including
any ground set forth in 18 U.S.C. § 3742(b), except that the United
States may appeal any sentence that is below the minimum penalty,

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Michelle R. Fox, Esquire
July 9, 2025 Re: Shamiese Wright

Page 8

if any, prescribed by statute.

Ms. Wright also knowingly and voluntarily waives the right to
challenge her guilty plea and conviction resulting from this plea
agreement, and any sentence imposed for the conviction, in any
collateral attack, including but not limited to a motion brought
under 28 U.S.C. § 2255.

The waivers noted above shall not apply to a post-conviction
collateral attack or direct appeal based on a claim of ineffective
assistance of counsel.

13. WAIVER OF FOIA AND PRIVACY RIGHT. Ms. Wright knowingly
and voluntarily waives all rights, whether asserted directly or by
a representative, to request or receive from any department or
agency of the United States any records pertaining to the
investigation or prosecution of this case, including without any
limitation any records that may be sought under the Freedom of
Information Act (FOIA), 5 U.S.C. § 552, or the Privacy Act of 1974,
5 U.S.C. § 552a, following final disposition.

14. FINAL DISPOSITION. The matter of sentencing is within
the sole discretion of the Court. The United States has made no
representations or promises as to a specific sentence. The United
States reserves the right to:

(a) Inform the Probation Office and the Court of all relevant
facts and conduct;

(b) Present evidence and argument relevant to the factors
enumerated in 18 U.S.C. § 3553(a);

(c) Respond to questions raised by the Court;

(d) Correct inaccuracies or inadequacies in the presentence
report;

(e) Respond to statements made to the Court by or on behalf

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Case 2:24-cr-00192 Document319 _ Filed07/14/25 Page 9 of 12 PagelD #: 1789

Michelle R. Fox, Esquire
July 9, 2025 Re: Shamiese Wright

Page 9

of Ms. Wright;

(f) Advise the Court concerning the nature and extent of Ms.
Wright’s cooperation; and

(g) Address the Court regarding the issue of Ms. Wright’s
acceptance of responsibility.

15. VOIDING OF AGREEMENT. Tf either the United States or
Ms. Wright violates the terms of this agreement, the other party
will have the right to void this agreement. If the Court refuses
to accept this agreement, it shall be void.

16. ENTIRETY OF AGREEMENT. This written agreement
constitutes the entire agreement between the United States and Ms.
Wright in this matter. There are no agreements, understandings

or recommendations as to any other pending or future charges
against Ms. Wright in any Court other than the United States
District Court for the Southern District of West Virginia.

Acknowledged and agreed to on behalf of the United States:

LISA G. JOHNSON

Assistant United

JTS/lab

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Michelle R. Fox, Esquire
July 9, 2025 Re: Shamiese Wright

Page 10

I hereby acknowledge by my initials at the bottom of each of the
foregoing pages and by my signature on the last page of this ten-
page agreement that I have read and carefully discussed every part
of it with my attorney, that I understand the terms of this
agreement, and that I voluntarily agree to those terms and
conditions set forth in the agreement. I further acknowledge that
my attorney has advised me of my rights, possible defenses, the
Sentencing Guideline provisions, and the consequences of entering
into this agreement, that no promises or inducements have been
made to me other than those in this agreement, and that no one has
threatened me or forced me-in any way to enter into this agreement.
Finally, I am satisfied with the representation of my attorney in
this matter.

Shamiése Wright if Date Signed
Defendant

Michelle R. Fox, Esquird Date Signed
Counsel for Defendant

Defendant’s
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Case 2:24-cr-00192 Document319 _ Filed 07/14/25 Page 11 of 12 PagelD #: 1791

UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF WEST VIRGINIA
CHARLESTON

UNITED STATES OF AMERICA

v. ‘ CRIMINAL NO. 2:24-cer-00192-2

SHAMIESE WRIGHT

STIPULATION OF FACTS

at

The United States and Shamiese Wright (hereinafter “I,” “me,
and “my”) stipulate and agree that the facts comprising the offense
of conviction (Count Two in the Second Superseding Indictment in
the Southern District of West Virginia, Criminal No. 2:24-cr-
00192-2, include the following:

At all relevant times, I resided in Charleston, Kanawha
County, West Virginia, within the Southern District of West
Virginia.

Throughout 2021, I maintained a personal bank account with
Stride Bank, National Association (“Stride Bank”). I agree that
Financial Institution 1 participated in the Paycheck Protection
Program (“PPP”) by funding loans and was a “financial institution”
within the meaning of 18 U.S.C. § 20.

On or about April 19, 2021, Kisha Sutton submitted, with my
full knowledge and authorization, a PPP loan application on my
behalf to Financial Institution 1. The application, including
supplemental documents, contained materially false information in
at least two respects. First, the documents falsely represented
that I was self-employed and received $75,000 in gross income
during 2020. Second, Kisha Sutton submitted a fraudulent IRS Form
1040, Schedule C (“IRS Form 1040”) for tax year 2020. I never
earned $75,000 in gross income in 2020 or during any tax year. The
IRS Form 1040 was also never submitted by me to the IRS; it was
created for the sole purpose of obtaining a fraudulent PPP loan.
This information qualified me for a loan amount I otherwise would
not have been qualified to receive. Financial Institution 1
approved the fraudulent application.

PLEA AGREEMENT EXHIBIT A
1
Case 2:24-cr-00192 Document319_ Filed 07/14/25 Page 12 of 12 PagelD #: 1792

On or about May 7, 2021, I received a $15,625 ACH transfer
disbursed by Financial Institution 1, and the funds were
electronically deposited in my Stride Bank checking account. At
the time I received the funds, I knew the $15,625 represented
proceeds from the fraudulent PPP loan. ,

Between May 7, 2021, and May 21, 2021, I used CashApp to
transfer $3,000 to Kisha Sutton from the fraudulent PPP loan
proceeds as compensation for facilitating the submission of my
fraudulent loan and consistent with our agreement... Kisha Sutton

provided instructions on how the payments were to be made to her.
On May 14, 2021, while I was in Charleston, Kanawha County, West
Virginia, within the Southern District of West Virginia, I sent
Kisha Sutton $1,000 via CashApp and disguised the nature of the
transaction by writing an electronic transfer description that was
wholly unrelated to the true purpose of the transaction. I
staggered my payments to Kisha Sutton and provided misleading
transfer descriptions for the purpose of concealing and disguising
the nature and the source of the money.

I spent the remainder of the loan proceeds on personal
expenses.

Stipulated and agreed t

SHAMTESE Mons.ohe. V Date
feydant
PA Uae R. Fox, Esquire Date

Counsel for D

. Storage Date
ant United State ney

PLEA AGREEMENT EXHIBIT A
2


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