United States v. Yashica Monique Carter — Plea Agreement, Middle District of Florida (Document 175)
Summary
A plea agreement between the United States and defendant Yashica Monique Carter, filed July 24, 2026 as Document 175 in Case No. 8:25-cr-00516-WFJ-CPT in the U.S. District Court for the Middle District of Florida. Carter agrees to plead guilty to Count One, conspiracy to commit wire fraud, which carries a maximum sentence of 30 years imprisonment; Count Ten is to be dismissed at sentencing. The agreement provides for full restitution to the Small Business Administration, forfeiture of proceeds and cooperation that the government agrees to consider for a substantial-assistance motion. The factual basis states that Lender #3 wired $20,330 in PPP funds to an account controlled by Carter after a second PPP application, and that Carter kicked back $4,000 to Breus days later. The 22-page agreement names defense attorney Patrick Leduc and United States Attorney Gregory W. Kehoe.
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“United States v. Yashica Monique Carter — Plea Agreement, Middle District of Florida (Document 175).”
Original at ecf.flmd.uscourts.gov. Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/plea-agreement-usa-v-breus-et-al-dkt-175-m-d-fla-074dec0cf6/
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Case 8:25-cr-00516-WFJ-CPT Document 175 Filed 07/24/26 Page 1 of 22 PageID 374
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UNITED STATES DISTRICT COURT
MIDDLE DISTRICT OF FLORIDA
TAMPA DIVISION
UNITED STATES OF AMERICA
CASE NO. 8:25-cr-516-WIJ-CPT
YASHICA MONIQUE CARTER
PLEAAG
Pursuant to Fed. R. Crim. P. l1(c), the United States of America, by Gregory
W. Kehoe, United States Attomey for the Middle District of Florida, and the
defendant, Yashica Carter, and the attorney for the defendant, Patrick Leduc,
mutually agree as follows:
A. ParticularizedTerms
1. Count Pleading To
The defendant shall enter a plea of guilty to Count One of the
Indictment. Count One charges the defendant with Conspiracy to Commit Wire
Fraud, in violation of l8 U.S.C. 0 1349.
2, Maximum Penalties
Count One carries a maximum sentence of 30 years impdsonment, a
fine of$1,000,000, 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 ofthe
offense, and with respect to other offenses, the Court may order the defendant to
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make restitution to any victim of the offense, or to the communify, as set forth
below.
3. Aoprendi t New letsE
Under Apprendi v. New Jmey,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 esrablished by this plea ofguitty: 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. 0g 5121-5207.
4. Elem nts ofthe ense
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 One are:
First Two or more persons, in some way or manner, ageed to try to
accomplish a cofllmon and unlawful plan to commit wire
fraud, as charged in the indictment; and
Second: The defendant knew the unlawful purpose of the plan and
willtully joined in it.
The elements of wire fraud, in violation of 18 U.S.C. $ 1343, 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;
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Third The defendant acted with the intent to defraud; and
Fourth The defendant transmitted or caused to be transmitted by wire
some corrununication in interstate cornmerce to help carry out
the scheme to defraud.
5. Cou nts D ismissed
At the time of sentencing, dr. lsm2ining count against the defendant,
Count Ten, will be dismissed pursuant to Fed. R. Crim. p. l l(c)(l)(A).
6. No Further Charges
If the Court accepts this plea agreement, the United States Attomey,s
oftice for the Middle District of Florida agrees not ro charge defendant with
committing any other federal criminal offenses known to the united states
Attomey's office at the time of the execution of this agreement, related to the
conduct giving rise to this plea agreement.
7.M torv Re stitution to Victim of Offense of Conv on
Pursuant to 18 U.S.C. $ 3663A(a) and (b), defendant agrees to make fulI
restitution to small Business Administration in the amount of $l15,g60.59. 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. Gui lines Se ntence
Pursuant to Fed. R. Crim. p. l1(c)(1)(B), the United States 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
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Sentencing Guidelines, as adjusted by any departure the united states has agreed to
recommend in this plea agreement. The parties understand that such a
recommendation is not binding on the court and that, if it is not accepted by this
court, neither the united 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
of guilry.
9 - Thre
At the time of sentencing, and in the event that no adverse information
is received suggesting such a recommendation to be unwarranted, the united States
will not oppose the defendant's request to the Court that the defendant receive a two-
level downward adjustment for acceptarce of responsibility, pursuant to USSG
$ 3E1.1(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 of subsection (a) is level 76 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 limited to, the timely submission of the financial affidavit
referenced in Paragraph B.5., the United States agrees to file a motion pursuant to
USSG $ 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 adjustrnent of a third level for acceptance of responsibility rests solely
ri,,,
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with the United States Attorney for the Middle District of Florida, and the defendant
agrees that the defendant cannot and will not challenge that determination, whether
by appeal, collateral attack, or otherwise.
10. Coooera tion - Substantial ssistance to be Considered
Defendant agrees to cooperate fully with the United States in the
investigation and prosecution ofother persons, and to testifi, 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 and other
matters, such cooperation to further include a full and complete disclosure of all
relevant information, including production of any and all books, 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 "substantial assistance" in accordance with the policy of the united states
Attomey for the Middle District of Florida, warranting the filing of a motion at the
time of sentencing recommending (l) a downward departure from the applicable
guideline range pursuant to USSG $5K1.1, or (2) the imposition of a sentence below
a statutory minimum, if any, pursuant to l8 U.S.C. g 3553(e), or (3) both. If the
cooperation is completed subsequent to sentencing, the government agrees to
consider whether such cooperation qualifies as "substantial assistance" in accordance
with the policy of the United States Attorney for the Middle District of Florida,
wananting the filing of a motion for a reduction of sentence within one year of the
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imposition of sentence pursuant to Fed. R. Crim. p. 35O). In any case, the
defendant understands that the determination as to whether "substantial assistance"
has been provided or what type of motion related thereto will be 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.
1I . Use of Information - Section 18 I .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 shall be used in determining
the applicable sentencing guideline range, subject to the restrictions and limitations
set forth in USSG glB1.8(b).
12. n-
a. The govemment will make known to the Court and other
relevant authorities the nature and extent of defendant's cooperation and any other
mitigating circumstances indicative of the defendant's rehabilitative intent by
assuming the fundamental civic duty of reporting crime. However, the defendant
understands that the government can make no representation that the court will
impose a lesser sentence solely on account of, or in consideration of, such
cooperation.
b. It is understood that should the defendant knowingly provide
incomplete or untruth-frrl testimony, statements, or information pursuant to this
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agreement, or should the defendant falsely implicate or incriminate any person, or
should the defendant fail to volunta ly and unreservedly disclose and provide full,
complete, truthful, and honest knowledge, information, and cooperation regarding
any of the matters noted herein, the following conditions shall apply:
(1) The defendant may be prosecuted for any perjury or false
declarations, if arry, committed while testiSring pursuart 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 ref e such charges and prosecute the defendant thereon in
tre event such charges have been dismissed pursuant to this agreement. with regard
to such charges, if any, which have been dismissed, ttre 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 indictrnent of a grand jury,
and further being aware that all such felony charges in the instant case have
heretofore properly been returned by the indictment of a grand jury, does hereby
agree to reinstatement ofsuch charges by recision ofany order dismissing them or,
altematively, 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 trial 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 :!s to any such offenses.
(4) The govemment may use against the defendant the
defendant's own admissions and statements and the information and bool$, papers,
documents, and objects that the defendant has fumished in tl,e 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 will be entitled to the sentencing limitations, if any, set
forth in this plea agreement, 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 Couft to declare this entfue plea agreement null and void.
13. Fo lture of Assets
The defendant agrees to forfeit to the United States irnrnediately 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.
92a61@), 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 $107,g30.00
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in proceeds the defendant admits she 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 of the defendant, the
proceeds have been transferred to thfud parties and cannot be located by the united
States upon the exercise ofdue diligence. Therefore, the defendant aglees that,
pursuant to 21 U.S.C. $ 853(p), the United States is entitled to forfeit any other
property 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 ofthe forfeiture order into the Treasury offset
Program. The defendant agrees that forfeiture of substitute assets as authorized
herein shall not be deemed an alteration of the defendant's sentence.
The defendant additionally agees that since the criminal proceeds have
been transferred to third parties and cannot be located by the United states upon the
exercise of due 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), pursuant to Rule 32.2@)(3) of the Federal Rules of Criminal
Procedure, to help identifu, locate, and forfeit substitute assets.
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The defendant also agrees to waive all constitutional, statutory, and
procedural challenges (including dire ct 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
Facrual 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 the preliminary order of forfeiture will satisfu tlle 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 identifr and locate
all substitute assets and to transfer custody ofsuch assets to the united states before
the defendant's sentencing. To that end, the defendant agrees to make a fulI and
complete disclosure ofall assets over which 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 ary records of assets owned by the
defendant, and to consent to the release of the defendant's tax returns for the
L
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 of assets, if it is deemed necessary by the United States.
The defendant agrees that Federal Rule of Criminal Procedure 11 and USSG $ 181.8
will 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 full 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 of any other documents necessary to
effectuate such transfers.
Forfeiture of the defendant's assets shall not be treated as satisfaction of
any fine, restitution, cost of imprisonment, or any other penalty ttre 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, notwithstanding 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 determination shall be
binding upon defendant's heirs, successors and assigns until the agreed forfeiture,
including the forfeiture ofany substitute assets, is final.
B. Standard Temrs and Conditions
1 Ilpctitrrtinn (npnial scecctnenf and Fin
The defendant understands and agrees that the Court, in addition to or
in lieu ofany other penalty, shall order the defendant to make restinrtion to any
victim of the offense(s), pursuant to 18 U.S.C. S 36634, for all offenses described in
18 U.S.C. S 3663A(cX1); and the Court may order the defendant to make restitution
to any victim of the offense(s), pursuant to 18 U.S.C. S 3663, including restitution as
to all counts charged, whetier or not the defendant enters a plea of guilty to such
counts, and whether or not such counts are dismissed pursuant to tiis 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 restitution (28 U.S.C.
S 30030)(2), including, but not limited to, garnishment 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. g 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. Suoervised Release
The defendant understands that the offense to which the defendant is
pleading provides for imposition ofa term 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.
3 ces
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 office all information conceming the background,
character, and conduct of the defendant, to provide relevant factual information,
including the totality of the defendant's criminal activities, if any, not limired to rhe
count(s) to which defendant pleads, to respond to comments made by the defendant
or defendant's counsel, and to corect any misstatements or inaccuracies. The
United States further reserves its right to make any recommendations it deems
appropriate regarding the disposition of this case, subject to any limitations set forth
herein, if any.
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5. Financial osures
Pursuant to 18 U.S.C. S 3664(d)(3) and Fed. R. Crim. p. 32(dX2XA)(ii),
the defendant agrees to complete and submit to the united States Attomey's office
within 30 days of execution of this agreement an affidavit reflecting the defendant's
financial condition. The defendant promises that his financial 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 third 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 of the defendant's tax returns for the previous five
years. The defendant similarly agrees and authorizes the united States Attorney's
Offrce 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 concerning the defendant, for the
pu{pose 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 Attorney's office to obtain current credit
reports in order to evaluate the defendant's ability 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 acceptor 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 recommendations and
present arguments to the Court, the sentence will be determined solely by the Coun,
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 attorney or other agents for the govemment regarding
any recommetrdations 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 govemment
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 govemment's recommendations contained herein.
7. De t's waiv of Rieh t to Apoeal the Sentence
The defendant agrees that this Court has jurisdiction and autlority 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 bv the court pursuant to
the
United States sentencing Guidelines; (b) the ground that the sentence exceeds the
statutory maximum penarry; or (c) the ground that the sentence violates the Eighth
Amendment to the constitution; provided, however, that if the govemment exercises
its right to appeal the sentence imposed, as authorized by lg U.S.c. g 3742(b),
then
the defendant is released from his waiver and may appeal the sentence as authorized
by 18 U.S.C. g 3742(a).
8 Dis I
It is further understood that this agreement is limited to the office of the
united States Aftomey 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 officers or
others, if requested.
9 il
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.
10. Voluntariness
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 govemment and the defendant and
defendant's attomey and without promise of benefit of an y kind (other than the
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390
concessions contained herein), and without threats, force, intimidation, or coercion
of any 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 defendaat'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 already 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 ilghts 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 will 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 serye on a jury, or to have possession of fuearms.
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11. Factual Basis
Defendant is pleading guilty because defendant is in fact guilty. 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 and others beyond a reasonable doubt.
FACTS
The United States Small Business Administration (SBA) was an
executive branch agency ofthe united states govemment that provided support to
enfiepreneurs and small businesses. The sBA enabled and provided for loans
through banks, credit unions, and other lenders. These loans had govemment-backed
guarantees. In addition to traditional SBA funding programs, the coronavirus Aid,
Reliei and Economic Security CARES Act, which was signed into Iaw in March
2020, established several new temporary progarns and provided for the expansion of
others to address a Presidentially declared disaster, the covlD-l9 outbreak.
one govemment response to the covlD-l9 outbreak was the creation
ofa 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 quatfring business expenses (i.e., payroll, rent,
mortgage interest, or utilities).
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SBA lender or any
Interested applicants applied through an existing
othelparticipatingfederally-insuredfrnancialinstitution.ThePPPapplication
an SBA
process required applicants to submit a Borrower Application Form though
approvedfinancialentity'Theapplicationcontainedinformationastotlrepurposeof
of employees' and background of the
the loan, aveftgemonthly payroll, number
business and its owner. Applicants were
also required to make certain good faith
had necessitated their loan
certifications, including that economic uncertainties
proceeds only for the authorized purposes'
PPP applications submitted through August
8'2020' were received
located in sterling, virginia' sBA
through the SBA E-Tran server which was
lender through the FMS system to the
transmitted the PPP processing fee to the
Treasury. Applications submitted after January
t'2021' were received through the
Summit plaform, a cloud-based pladorm
utilizing the AWS GOV cloud servers
to the borrower' PPP lenders submitted
located in Oregon. After sending the funds
system in Sterling' Virginia'
disbursement details into the SBA E-Tran
and continuing through
Beginning as early as in or around Apn12020'
atleastinoraroundJune202l,intheMiddleDistlictofFlolidaandelsewhele,the
Yashica Carter' and others did knowingly and
willfully
defendants Sherell Breus,
combine, conspire, confederate, and agree
with each other and others' to commit
was to use false and fraudulent
wire fraud. The purpose of the illegal scheme
government programs to which the
information to obtain loans ftom federal
consPirators were not entitled'
Defendant's Initials
J/
I \---/ t9
Case 8:25-cr-00516-WFJ-CPT Document 175 Filed 07/24/26 Page 20 of 22 PageID
393
For instance, on or about May 27,2020, Carter, with the assistance ot
co-conspirator Breus, submitted a false and fraudulent PPP loan application for her
business Genuine care Transport, LLC. Just a few days before submitting this
application Carter filed paperwork with the Florida Department of State to reinstate
the business into an "active" status, as the business had failed to file an annual report
in 2019. Carter's PPP application falsely claimed Genuine Care had 6 employees
with an averagemonthly payroll of$35,000. In support ofher false payroll numbers,
Carter submitted a fraudulent payroll ledger and a fraudulent IRS From 944
Employer's Annual Federal Tax Retum for tax yeal 2019. The payroll ledger is in
the exact format as other payroll ledgers submitted by Breus to PPP lenders.
Additionally, this payroll ledger claimed co-conspfuatol candice Harper's young
child was an employee of her business'
As a result of Carter's fraudulent PPP application, or.May 28, 2020'
Lender #1 ffansmitted an interctate wire payment in the amount of $87,500 in
PPP
fund sent from outside the state of Florida to a Financial Institution #5 account
ending in 7826locatedithe Middle District of Florida. carter was the only
authorized signer on this account.
In 2027, Carter with the help of Breus submitted another false and
fraudulent PPP application, this time for her sole proprietor business. This
grossed
application falsely claimed carter owned a business with one employee that
$gT,000rr-2o2o.ThisapplicationalsoincludedafalseandfraudulentIRS1040
schedule C Profit or Loss From Business for tax year 2020. This Schedule
c is a near
Defendanfs Initials 20
Case 8:25-cr-00516-WFJ-CPT Document 175 Filed 07/24/26 Page 21 of 22 PageID
394
identical copy to the fraudulent Schedule Cs submitted by Breus and Harper for their
2021 sole proprietor PPP loans. As a result of the material misrepresentations
contained in Carter's second PPP application, on April 20,,2021, Lender #3
ftansmitted an interstate wire payment of $20,330 in PPP funds from outside the
state of Florida into a Financial Institution #4 accotnt ending in 6672 cofirolled,by
Carter, located in the Middle District of Florida. Days after receiving this loan,
Carter kicked back $4,000 ofher fraudulently obtained funds to Breus via a peer-to-
peer transfer platform. These funds were deposited into Breus's Financial Institution
# I account ending in 29 15.
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, percons involved, or other information
relating to this case.
12. Entire Agreement
This plea agreement constitutes the entire agreement between the
govemment and the defendant with respect to the aforementioned guilty plea arrd no
other promises, agreements, or representations exist or have been made to the
defendant or defendant's attomey with rcgard, to such guilty plea.
Defen dant's Initials l) 2T
Case 8:25-cr-00516-WFJ-CPT Document 175 Filed 07/24/26 Page 22 of 22 PageID
395
13. Certification
The defendant and defendant's counsel certify that this plea agreement
has been read in its entirety by (or has been read to) the defendant and tlat defendant
fully understands its terms.
DATED rhis 3V day o f&l 2026
GREGORYW. KEHOE
United States Attomey
Y Monique Carter yn E. Ho
United Attomey
'2/'),/
Patri Leduc Michael R. Kenneth
Attorney for Defendant Assistant United States AttomeY
Chief, Economic Crimes Section
22
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