United States v. Raymond Carvil Sr. — Plea Agreement, Middle District of Florida (Document 161)
Summary
A plea agreement between the United States and defendant Raymond Carvil Sr., filed June 2, 2026 as Document 161 in Case No. 8:25-cr-00516-WFJ-CPT in the U.S. District Court for the Middle District of Florida. Carvil agrees to plead guilty to Count Six, which charges wire fraud and carries a maximum sentence of 30 years imprisonment; Count One is to be dismissed at sentencing. The agreement provides for full restitution of $103,312.08 to the Small Business Administration and forfeiture of $97,500 in proceeds. Carvil agrees to cooperate, and the government agrees to consider whether that cooperation qualifies as substantial assistance. The factual basis states that Carvil kicked back $19,500 of PPP funds to co-conspirator Breus. The 21-page agreement names defense attorney Larry Handfield and United States Attorney Gregory W. Kehoe.
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“United States v. Raymond Carvil Sr. — Plea Agreement, Middle District of Florida (Document 161).”
Original at ecf.flmd.uscourts.gov. Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/plea-agreement-usa-v-breus-et-al-dkt-161-m-d-fla-6569940710/
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Case 8:25-cr-00516-WFJ-CPT Document 161 Filed 06/02/26 Page 1 of 21 PageID 329
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UNITED STATES DISTRICT COURT
MIDDLE DISTRICT OF FLORIDA
TAMPADIVISION
LINITED STATES OF AMERICA
CASE NO. 8:25-cr-5 1 6-WFJ-CPT
RAYI\,IOND CARVIL SR.
PLEAAGREEMENT
Pursuant to Fed. R. Crim. P. l1(c), the United c ,es ofAmerica, by Gregory
W. Kehoe, United States Attorney for the Middl, , . ;irict of Florida, and the
defendant, Raymond Carvil Sr., and the attomey for the defendant, Larry Handfield,
mutually agree as follows:
A. ParticularizedTerns
l. Count Pleading To
The defendant shall enter a plea of guilty to Count Six of the
Indictment. Count Six charges the defendant with Wire Fraud, in violation of 18
u.s.c.0 1343.
2. Maximum Penalties
Count Six carries a maximum sentence of 30 years imprisonment, a fine
of$I,000,000, a term of supervised release ofnot more than 5 years, and a special
assessment of $100 per felony count for individuals. With respect to certain offenses,
the court shall order the defendant to make restitution to any victim of the offense,
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and with respect to other offenses, the Court may order the defendant to make
restitution to any victim of the offense, or to the community, as set forth below.
3. Arutrendi v. New Jetsqt
Utder Apprenditt. New lersey,530 U.S. 466 (2000), a maximum sentence
of 30 years imprisonment may be imposed because the following facts have been
admitted by the defendant and are established by this plea ofguilty: the defendant
received a benefit that was paid in connection with a major disaster declaration
under section 501 of the Robert T. Stafford Disaster Relief and Emergency
Assistance Act,42 U.S.C. $$ 5121-5207.
4. Elenoents of the Offense
The defendant acknowledges understanding the nature and elements of
the offense with which defendant has been charged and to which defendant is
pleading guilty. The elements of Count Six are:
First: The defendant knowingly devised or participated in a scheme
to defraud, or obtain money or property by using false
pretenses, representations, or promises;
Second: The false pretenses, representations, or promises were about a
material fact;
Third: The defendant acted with the intent to defraud; and
Fourth: The defendant transmitted or caused to be transmitted by wire
some communication in interstate commerce to help carry out
the scheme to defraud.
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5. Counts Dismissed
At the time of sentencing, the remaining count against the defendant,
Count One, will be dismissed pursuant to Fed. R. Crim. P. 11(c\l)(A).
6. No Further Charges
If the Court accepts this plea agreement, the United States Attomey's
Office for the Middle District of Florida agrees not to charge defendant with
committing any other federal criminal offenses known to the United States
Aftomey's Office at the time of the execution of this agreement, related to the
conduct giving rise to this plea agreement.
7 on
Pursuant to 18 U.S.C. $ 18 U.S.C. U.S.C. g 3663A(a) and (b),
defendarfi agrees to make fuIl restitution to Small Business Administration in the
amount of $103,312.08. The restitution amount includes the loan principle received
by the defendant as well as the lender processing fee, and forgiven interest. The final
amount of restitution and all specific recipients will be determined by the Court at
the time of sentencing.
8. Guidelines Sentence
Pursuant to Fed. R. Crim. P. 11(c)(1)@), the United Srates will
recommend to the Court that the defendant be sentenced within the defendant's
applicable guidelines range as determined by the Court pursuant to the United States
Sentencing Guidelines, as adjusted by any departure the United States has agreed to
recommend in this plea agreement. The parties understand that such a
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recommendation is not binding on the Court and that, if it is not accepted by this
Court, neither the Udted States nor the defendant will be allowed to withdraw from
the plea agreement, and the defendant will not be allowed to withdraw from the plea
ofguilty.
9,A
At the time of sentencing, and in the event tllat no adverse information
is received suggesting such a recommendation to be unwarranted, the United States
will not oppose the defendant's request to ttre Court that the defendant receive a two-
level downward adjustment for acceptance of responsibility, pursuant to USSG
$ 3E 1 . 1(a). The defendant understands that this recommendation or request is not
binding on the Court, and if not accepted by the Court, the defendant will not be
allowed to withdraw from the plea.
Further, at the time of sentencing, if the defendant's offense level prior
to operation ofsubsection (a) is level 16 or greater, and if the defendant complies
with the provisions of USSG $ 3E1.1(b) and all terms of this plea Agreement,
including but not [mited to, the timely submission of the financial affidavit
referenced in Paragraph 8.5., the united states agrees to file a motion pursuant to
ussc $ 3E1.1(b) for a downward adjustment of one additional level. The defendant
understands that the determination as to whether the defendant has qualified for a
downward adjustment of a third leve1 for acceptance of responsibility rests solely
with the united states Anorney for the Middle District of Florida, and the defendant
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agrees that the defendant canaot and will not challenge that determination, whether
by appeal, colateral attack, or otherwise.
10. Coooeration - Sub stan tial Assistance to be Considered
Defendaat agrees to cooperate fully with the United States in the
investigation and prosecution ofother persons, and to testi[2, subject to a prosecution
for perjury or making a false statement, fully and truthfully before any federal court
proceeding or federal grand jury in connection with the charges in this case arrd other
matters, such cooperation to further include a full and complete disclosure of all
relevant information, including production ofany and all boots, papers, documents,
and other objects in defendant's possession or control, and to be reasonably available
for interviews which the United States may require. If the cooperation is completed
prior to sentencing, the govemment agrees to consider whether such cooperation
qualifies as "zubstantial assistance" in accordance with the policy of the United States
Attorney for the Middle Disrict of Florida, warranting the filing of a motion at the
time of sentencing recommending (1) a downward departure from the appl_icable
guideline range pursuant to USSG $5K1.1, or (2) the imposition of a sentence below
a statutory minimum, if any, pursuant to 18 U.S.C. $ 3553(e), or (3) both. If the
cooperation is completed subsequent to sentencing, the govemment agrees to
consider whether such cooperation qualifies as "substantial assistance,, in accordance
with the potcy of the United srates Anomey for the Middle District of Florida,
warlanting the filing of a motion for a reduction of sentence within one year of the
imposition of sentence pursuant to Fed. R. Crim. p. 35(b). In any case, the
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defendant understands that the determination as to whether "substantial assistance"
has been provided or what type of motion related thereto wil1be filed, if any, rests
solely with the United States Attorney for the Middle District of Florida, and the
defendant agrees that defendant cannot and will not challenge that determination,
whether by appeal, collateral attack, or otherwise.
11. Use of Informatioa: Sectipn 181-8
Pursuant to USSG $1B1.8(a), the United States agrees that no self-
incriminating information which the defendant may provide during the course of
defendant's cooperation and pursuant to this agreement shal1 be used in determining
the applicable sentencing guideline range, subject to the restrictions and limitations
set forth in USSG $1B1.8(b).
72 ibilities
a. The government will make known to the Court and other
relevant authorities the nature and extent of defendant's cooperation and any other
mttigating circumstances indicative of the defendant's rehabilitative intent by
aszuming the fundamental civic duty of reporting crime. However, the defendant
understands that the govemment can make no representation that the Court will
impose a lesser sentence solely on account of, or in consideration of, zuch
cooperation.
b. It is understood that should the defendant knowingly provide
incomplete or untruthful testimony, statements, or information pursuant to this
agreement, or should the defendant falsely implicate or incriminate any peruon, or
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should the defendant fail to voluntarily and unreservedly disclose and provide firll,
complete, truthful, and honest knowledge, inforrnation, and cooperation regarding
any of the matters noted herein, the following conditions shall apply:
(1) The defendant may be prosecuted for any pet'ury or false
declarations, if any, committed while testiffing pursuant to this agreement, or for
obstruction of justice.
(2) The United States may prosecute the defendant for the
charges which are to be dismissed pursuant to this agreement, if any, and may either
seek reinstatement ofor refile such charges and prosecute the defendant thereon in
the event such charges have been dismissed pursuant to this agreement. With regard
to such charges, if any, which have been dismissed, the defendant, being fully aware
of the nature of all such charges now pending in the instant case, and being further
aware of defendant's rights, as to all felony charges pending in such cases (those
offenses punishable by imprisonment for a term of over one year), to not be held to
answer to said felony charges unless on a presentment or indictment of a grand jury,
and frrrther being aware that all such felony charges in the instant case have
heretofore properly been retumed by the indictment of a grand jury, does hereby
agree to reinstatement ofsuch charges by recision ofany order dismissing them or,
alternatively, does hereby waive, in open court, prosecution by indictment and
consents that the united states may proceed by information instead of by indictment
with regard to any felony charges which may be dismissed in the instant case,
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pursuant to this plea agreement, and the defendant further agrees to waive the statute
of limitations and any speedy rial claims on such charges.
(3) The United States may prosecute the defendant for any
offenses set forth herein, if any, the prosecution of which in accordance with this
agreement, the United States agrees to forego, and the defendant agrees to waive the
statute of limitations and any speedy trial claims as to any such offenses.
(4) The govemment may use against the defendant the
defendant's own admissions and statements and the information and books, papers,
documents, and objects that the defendant has fumished in the course of the
defendant's cooperation with the government.
(5) The defendant will not be permitted to withdraw the guilty
pleas to those counts to which defendant hereby agrees to plead in the instant case
but, in that event, defendant vrill be entitled to the seatencing limitations, if any, set
forth in this plea agreerment, with regard to those counts to which the defendant has
pled; or in the altemative, at the option of the United States, the United States may
move the Court to declare this entire plea agreement null and void.
13. Forfeiture of Assets
The defendant agrees to forfeit to the United States immediately and
voluntarily any and all assets and property, or portions thereof, subject to forfeiture,
pursuant to 18 U.S.C. g 981(a)(1)(C) and 28 U.S.C. g2 6t@), whether in the
possession or control of the united states, the defendant or defendant's nominees.
The assets to be forfeited specifically include, but are not limited to, the $97,500 in
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proceeds the defendant admits he obtained, as the result of the commission of the
offense to which the defendant is pleading guilty. The defendant acknowledges and
agrees that: (1) the defendant obtained this amount as a result of the commission of
the offense(s), and (2) as a result of the acts and omissions ofthe defendant, the
proceeds have been transferred to third parties and cannot be located by the United
States upon the exercise of due diligence. Therefore, the defendant agrees that,
pursuant to 21 U.S.C. $ 853(p), the United States is entitled to forfeit any other
properry of the defendant (substitute assets), up to the amount ofproceeds the
defendant obtained, as the result of the offense(s) of conviction. The defendant
further consents to, and agrees not to oppose, any motion for substitute assets filed
by the United States up to the amount of proceeds obtained from commission of the
offense(s) and consents to the entry of the forfeiture order into the Treasury Offset
Program. The defendant agees that forfeiture of substitute assets as authorized
herein shall not be deemed an alteration of the defendant's sentence.
The defendaat additionally agrees that since the criminal proceeds have
been transferred to third parties and cannot be located by the United States upon the
exercise ofdue diligence, the preliminary and final orders of forfeiture should
authorize the United States Attomey's Office to conduct discovery (including
depositions, interrogatories, requests for production of documents, and the issuance
of subpoenas), pursuanr to Rule 32.2(b)(3) of the Federal Rules of Criminal
Procedure, to help identift, locate, and forfeit substitute assets.
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The defendant also agrees to waive all constitutional, statutory, and
procedural challenges (including direct appeal, habeas corpus, or any other means) to
any forfeiture carried out in accordance with this Plea Agreement on any grounds,
including that the forfeiture described herein constitutes an excessive fine, was not
properly noticed in the charging instrument, addressed by the Court at the time of
the guilty plea, announced at sentencing, or incorporated into the judgment.
The defendant admits and agrees that the conduct described in the
Facnral Basis below provides a sufficient factual and statutory basis for the forfeiture
of the property sought by the govemment. Pursuant to Rule 32.2(b)(4), the
defendant agrees that fhe preliminary order of forfeiture will satisfu the notice
requirement and will be final as to the defendant at the time it is entered. In the
event the forfeiture is omitted from the judgment, the defendant agrees that the
forfeiture order may be incorporated into the written judgment at any time pursuant
to Rule 36.
The defendant agrees to take all steps necessary to identifu and locate
all substitute assets and to transfer custody of zuch assets to the United States before
the defendant's sentencing. To that end, the defendant agrees to make a full and
complete disclosure of all assets over rvhich defendant exercises control, including all
assets held by nominees, to execute any documents requested by the United States to
obtain from any other parties by lawful means any records of assets owned by the
defendant, and to consent to the release of the defendant's tax retums for the
previous five years. The defendant agrees to be interviewed by the govemment,
prior
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to and after sentencing, regarding such assets. The defendant further agrees to be
polygraphed on the issue ofassets, if it is deemed necessary by the United States.
The defendant agrees that Federal Rule of Criminal Procedure 1 1 and USSG S 1B L8
\ ill not protect from forfeiture assets disclosed by the defendant as part of the
defendant's cooperation.
The defendant agrees to take all steps necessary to assist the
govemment in obtaining clear title to any substitute assets before the defendant's
sentencing. In addition to providing fulI and complete information about substitute
assets, these steps include, but are not limited to, the surrender of title, the signing of
a consent decree of forfeiture, and signing ofany other documents necessary to
effectuate such transfers.
Forfeiture of the defendant's assets shall not be treated as satisfaction of
any fine, restitutioo, cost of imprisonment, or any other penalty the Court may
impose upon the defendant in addition to forfeiture.
The defendant agrees that, in the event the Court determines that the
defendant has breached this section of the Plea Agreement, the defendant may be
found ineligible for a reduction in the Guidelines calculation for acceptance of
responsibility and substantial assistance, and may be eligible for an obstruction of
justice enhancement.
The defendant agrees that the forfeiture provisions of this plea
agreement are intended to, and will, survive the defendant, nofwithstanding the
abatement of any underlying criminal conviction after the execution of this
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agreement. The forfeitability of any particular properry pursuant to this agreement
shall be determined as if the defendant had survived, and that detemination shall be
binding upon defendant's heirs, successors and assigns until the agreed forfeiture,
including the forfeiture ofany substitute assets, is final.
B. Standard Terms and Conditions
1. Restitution. Special Assessment and Fine
The defendant understands and agrees that the Court, in addition to or
in lieu of any other penalty, shall order the defendant to make restitution to any
victim of the offense(s), pursuant to 18 U.S.C. S 3663A, for all offenses described in
18 U.S.C. S 3663A(c)(1); and the Court may order the defendant to make restitution
to any victim of the offense(s), pursuant to 18 U.S.C. g 3663, including restitution as
to all counts charged, whether or not the defendant enters a plea of guilty to such
counts, and whether or not such counts are dismissed pursuant to this agreement.
The defendant.further understands that compliance with any restitution payment
plan imposed by the Court in no way precludes the United States from
simultaneously pursuing other statutory remedies for collecting restitufion (28 U.S.C.
S 3003(bX2), including, but not limited to, gamishment and execution, pursuant to
the Mandatory Victims Restitution Act, in order to ensure that the defendant,s
restitution obligation is satisfied.
On each count to which a plea of guilty is entered, the Court shall
impose a special assessment pursuant to 18 u.s.c. S 3013. The special assessment is
due on the date of sentencing.
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The defendant understands that this agreement imposes no limitation as
to fine.
2. Supervised Release
The defendant understands that the offense(s) to which the defendant is
pleading provide(s) for imposition ofa terrn of supervised release upon release from
imprisonment, and that, if the defendant should violate the conditions of release, the
defendant would be subject to a further term of imprisonment.
J of Ple Guil
The defendant has been advised and understands that, upon conviction,
a defendant who is not a United States citizen may be removed from the United
States, denied citizenship, and denied admission to the United States in the future.
4. Sentencinglnformation
The United States reserves its right and obligation to report to the Court
and the United States Probation OfEce all information conceming the background,
charader, and conduct of the defendant, to provide relevant factual information,
including the totality of the defendant's crimhal activities, if any, not limited to the
count(s) to which defendant pleads, to respond to comments made by the defendant
or defendant's counsel, and to correct any misstatements or inaccuracies. The
United States further reserves its right to make any recommendations it deems
appropriate regarding the disposition ofthis case, subject to any limitations set forth
herein, if any.
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5. FinancialDisclosures
Pursuant to 18 U.S.C. S 3664(dX3) and Fed. R. Crim. P. 32(dX2XAXii),
the defendant agrees to complete and submit to the United States Attorney's Office
within 30 days of execution ofthis agreement an affidavit reflecting the defendant's
financial condition. The defendant promises that his f,rnancial statement and
disclosures will be complete, accurate and truthful and will include all assets in
which he has any interest or over which the defendant exercises control, directly or
indirectly, including those held by a spouse, dependent, nominee or other third party.
The defendant further agrees to execute any documents requested by the United
States needed to obtain from any thtd parties any records ofassets owned by the
defendant, directly or through a nominee, and, by the execution of this Plea
Agreement, consents to the release ofthe defendant's tax returns for the previous five
years. The defendant similarly agrees and authorizes the Udted States Attomey's
Office to provide to, and obtain from, the United States Probation Office, the
financial affidavit, any of the defendant's federal, state, and local tax retums, bank
records and any other financial information conceming the defendant, for the
purpose of making any recommendations to the Court and for collecting any
assessments, fines, restitution, or forfeiture ordered by the Court. The defendant
expressly authorizes the United States Attomey's Offrce to obtain current credit
reports in order to evaluate the defendant's abiliry to satisry any financial obligation
imposed by the Court.
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6. SentencingRecommendations
It is understood by the parties that the Court is neither a party to nor
bound by this agreement. The Court may accept or reject the agreement, or defer a
decision until it has had an opportunity to consider the presentence report prepared
by the United States Probation Office. The defendant understands and
acknowledges that, although the parties are permitted to make recornmendations and
present arguments to the Court, the sentence will be determined solely by the Court,
with the assistance of the United States Probation Office. Defendant further
understands and acknowledges that any discussions between defendant or
defendant's attomey and the attomey or other agents for the govemment regardng
any recommendations by the government are not binding on the Court and that,
should any recommendations be rejected, defendant will not be permitted to
withdraw defendant's plea pursuant to this plea agreement. The government
expressly reserves the right to support and defend any decision that the Court may
make with regard to the defendant's sentence, whether or not such decision is
consistent with the government's recommendations contained herein.
7. Defendant's Waiver of Risht to Apoeal the Sen tence
The defendant agrees that tlds Court has jurisdiction and authority to
impose any sentence up to the statutory maximum and expressly waives the right to
appeal defendant's sentence on any ground, including the ground that the Court
erred in determining the applicable guidelines range pursuant to the united states
Sentencing Guidelines, except (a) the ground that the sentence exceeds the
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defendant's applicable guidelines range as determined by the Court pursuant to the
United States Sentencing Guidelines; (b) the ground that the sentence exceeds the
statutory maximum penalty; or (c) the ground that the sentence violates the Eighth
Amendment to the Constitution; provided, however, that if the government exercises
its right to appeal the sentence imposed, as authorized by 18 U.S.C. S 3742(b), then
the defendant is released from his waiver and may appeal the sentence as authorized
by 18 U.S.C. S 37a2@).
8 Middle D istrict of Florida Asreement
It is further understood that this agreement is limited to the Office of the
United States Attomey for the Middle District of Florida and cannot bind other
federal, state, or local prosecuting authorities, although this office will bring
defendant's cooperation, if any, to the attention of other prosecuting offrcers or
others, if requested.
9. Filing of Agreement
This agreement shall be presented to the Court, in open court or in
camera, in whole or in part, upon a showing of good cause, and filed in this cause, at
the time of defendant's entry of a plea of guilty pursuant hereto.
1 0 . Vslu.ntariness
The defendant acknowledges that defendant is entering into this
agreement and is pleading guilty freely and voluntarily without reliance upon any
discussions between the attomey for the government and the defendant and
defendant's attomey and without promise of benefit of any kind (other than the
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concessions contained herein), and without threats, force, intimidation, or coercion
ofany kind. The defendant further acknowledges defendant's understanding of the
nature of the offense or offenses to which defendant is pleading guilty and the
elements thereof, including the penalties provided by law, and defendant's complete
satisfaction with the representation and advice received from defeadant's
undersigned counsel (if any) The defendant also understands that defendant has the
right to plead not guilty or to persist in that plea if it has akeady been made, and that
defendant has the right to be tried by a jury with the assistance of counsel, the right
to confront and cross-examine the witnesses against defendant, the right against
compulsory self-incrimination, and the right to compulsory process for the
attendance of witnesses to testifu in defendant's defense; but, by pleading guilty,
defendant waives or gives up those rights and there will be no trial. The defendant
further understands that if defendant pleads guilty, the Court may ask defendant
questions about the offense or offenses to which defendant pleaded, and if defendant
answers those questions under oath, on the record, and in the presence ofcounsel (if
any), defendant's answers may later be used against defendant in a prosecution for
perjury or false statement. The defendant also understands that defendant w.ill be
adjudicated guilty of the offenses to which defendant has pleaded and, if any of such
offenses are felonies, may thereby be deprived of certain rights, such as the right to
vote, to hold public office, to serve on a jury, or to have possession of
firearms.
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1 l. Factual Basis
Defendant is pleadrng guilty because defendant is in fact guilry. The
defendant certifies that defendant does hereby admit that the facts set forth below are
true, and were this case to go to trial, the United States would be able to prove those
specific facts atrd others beyond a reasonable doubt.
FACTS
The United States Small Business Administration (SBA) was an
executive branch agenry of the United States govemment that provided support to
entrepreneurs and small businesses. The SBA enabled and provided for loans
through banlcs, credit unions, and other lenders. These loans had government-backed
guarantees. In addition to traditional SBA funding programs, the Coronavirus Aid,
Relief, and Economic Security (CARES) Act, which was signed into law in March
2020, estabtshed several new temporary programs and provided for the expansion of
others to address a Presidentially declared disaster, the COVID-l9 outbreak.
One govemment response was the creation of a new loan program, the
SBA Paycheck Protection Program (PPP), which was a loan designed, in part, to
provide a direct incentive for small businesses to keep their workers on payroll.
Under this program, the SBA could forgive all or part of the borrowing business,s
loans provided that employees were kept on the payroll for eight weeks and
borrowers submitted documentation confirming that the loan proceeds were used for
certain qualifying business expenses (i.e., payroll, rent, mortgage interest, or utilities).
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Interested applicants applied through an existing SBA lender or any
other participating federally-insured financial institution. The PPP application
process required applicants to submit a Borrower Application Fomr through an SBA
approved furancial entity. The application contained information as to the purpose of
the loan, average monthly payroll, number of employees, and background of the
business and its owner. Applicants were also required to make certain good faith
certifications, including that economic uncertainties had necessitated their loan
proceeds only for the authorized purposes.
Beginning as early as in or around Apr1l2020, and continuing through
at least in or around I:une 2021 , in the Middle District of Florida and elsewhere, the
defendants Sherell Breus, Raymond Carvil Sr., and others did knowingly and
willfully combine, conspire, confederate, and agree with each other and others, to
commit wire fraud. The purpose of the illegal scheme was to use false and fraudulent
information to obtain loans from federal government programs to which the
conspirators were not entitled.
For instance, on or about June 10,2020, Carvil, with the assistance of
co-conspirators Breus and Harper, submitted a false and fraudulent ppp application
for his business E &S Securiry Agency, LLC. Carvil,s ppp application contained
numerous material misrepresentations including that his business had six employees
with an a\erage monthly payloll of 939,000. In support of Carvil,s purported payroll,
carvil submitted multiple false and fraudulent IRS Form w-2 for tax year 2019. one
of the fraudulent w-2s claimed co-conspirator Tameshia Roberson was employed by
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E & S Securiry Agency. Additionally, Carvil's PPP application included tfuee altered
,bank statements from a Financial Institution # 2t accottnt. These bank statements
were altered from co-conspirator Breus's account and edited to appear as if they
belonged to E & S Security's Agency's business bank account.
As a result of Carvil's fraudulent application, Lender #1 transmitted a
wire payment of $97,500 of PPP funds into Carvil's Financial Institution #5 account
ending in 6733. After receiving his PPP funds, Carvil kicked back a portion of his
loan to co-conspirator Breus. On or about Jrtly 22,2020, Carvil catsed an interstate
wire transmission of $19,500 of PPP funds sent from his Financial Institution #5
account ending in 6733 to Breus's Financial tnstitution #2 acconrtt ending in 3147
located in the Middle District of Florida. The servers used to process the payment
sent to Breus's Financial Instituion #2 account were located outside the state of
Florida.
The above is merely a summary of some of the events, some of the
persons involved, and other information relating to this case. It does not include, nor
is it intended to include, all the events, persotrs involved, or other information
relating to this case.
12. Entire Agteement
This plea agreement constitutes the entire agreement betweer the
govemment and the defendant with respect to the aforementioned guilty plea and no
I where
applicable, the Financial Insritution numbers conespond to the numbers listed in
the Indictment and are used consistently across all plea agreements.
Defendant's Initials 20
Case 8:25-cr-00516-WFJ-CPT Document 161 Filed 06/02/26 Page 21 of 21 PageID
349
other promises, agreements, or representations exist or have been made to the
defendant or defendant's attorney with regard to such guilfy p1ea.
1 3. Certification
The defendant and defendant's counsel certiry that this plea agreement
has been read in its entirety by (or has been read to) the defendant and that defendant
fully understands its terms.
DATED this \ 5 day of 2026
I
GREGORYW. KEHOE
United States Attorney
Raymond Carvil Sr. M E. Hoen ef
Defendant Assistant United es Attomey
.Z/' d/'
Michael R. Kenneth
Attomey for Defendant Assistaat United States Attomey
Chie( Economic Crimes Section
21
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