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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.

Summary drafted by a model from the text of the original file linked on this page and checked by script against that text before publication. It is a navigation aid, not a reading of what the document proves. Where AI is used

Cite this document

“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/, SHA-256 d9d06daf754665c64feaa26805ae46981962c79d0deaf70bbf1a24772e8fbb0f.

Full text

Case 8:25-cr-00516-WFJ-CPT       Document 161       Filed 06/02/26    Page 1 of 21 PageID 329


   AF Approval DCfor SCN                                          ChiefApproval %RK

                          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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                                          347




               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.


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                                          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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