United States v. Jessica A. Sejour — Plea Agreement, Middle District of Florida (Document 193)
Summary
A plea agreement between the United States and defendant Jessica A. Sejour, filed August 19, 2026 as Document 193 in Case No. 8:25-cr-00516-WFJ-CPT in the U.S. District Court for the Middle District of Florida. Sejour agrees to plead guilty to Count One, conspiracy to commit wire fraud, which carries a maximum sentence of 30 years imprisonment; Count Seven is to be dismissed at sentencing. The agreement provides for restitution to the Small Business Administration of at least $213,413.57, of which at least $182,760.58 was jointly obtained with co-conspirator Antwaun Johnson. It lists $187,300 in proceeds for forfeiture, with $159,900 jointly owed with co-defendant Antwaun Johnson and $27,400 owed by Sejour alone. Sejour agrees to cooperate, and the 22-page agreement names defense attorney Anthony M. Candela.
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“United States v. Jessica A. Sejour — Plea Agreement, Middle District of Florida (Document 193).”
Original at ecf.flmd.uscourts.gov. Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/plea-agreement-usa-v-breus-et-al-dkt-193-m-d-fla-3d8f5b4a8d/
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Case 8:25-cr-00516-WFJ-CPT Document 193 Filed 08/19/26 Page 1 of 22 PageID 455
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UNITED STATES DISTRICT COURT
MIDDLE DISTRICT OF FLORIDA
TAMPA DIVISION
UNITED STATES OF AMERICA
v. CASE NO. 8:25-cr-516-WFJ-CPT
IESSICA A. SEJOUR
PLEAAGREEMENT
Pursuant to Fed. R. Crim. P. 1l(c), the United States of America, by Gregory
W. Kehoe, United States Attorney for the Middle District of Florida, and the
defendant, Jessica A. Sejour, ard the attorney for the defendant, Anthony M.
Candela, mutually agree as follows:
A. Particularized Terms
1. Count Pleading To
The defendant sha1l enter a plea of guilty to Count One of the
Indictrnent. Count One charges the defendant with Conspirary to Commit \i/ire
Fraud, in violation of 18 U.S.C. $ 1349.
2. Maximum Penalties
Count One carries a maximum sentence of 30 years imprisonment, a
fine of $1,000,000, a terrn of supervised release of not more than 5 years, and a
special assessment of $100 per feiony count for individuals. With respect to certain
offenses, the Court shall order the defendant to make restitution to any victim of the
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 community, as set forth
below
3. Apprendi v. Nrw lersEt
Under Apprendi v. New Jercey,s30 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 of guilry: 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 Emergenry
Assistance Act,42 U.S.C. $$ 5121-5207.
4. Elements 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 One are:
First: Two or more persons, in some way or manner, agreed to try to
accomplish a common aad 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 scherne
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 communication in interstate commerce to help carry out
the scheme to defraud.
5. Counts Dismissed
At the time of sentencing, the remaining count against the defendant,
Count Seven, wil1be dismissed pursuant to Fed. R. Crim. P. 11(cXl)(A).
6. No Futher 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
Afforney's Ofiice at the time of the execution of this agreement, related to the
conduct giving rise to this plea agreement.
7. Mandatory Restitution to Victim of Offense of Conviction
Pursuant to 18 U.S.C. $ 3663A(a) and (b), defendant agrees to make full
restitution to Small Business Administration in the amount of at least $213,413.57.
The restitution amount includes the loan principle received by the defendant as well
as the processing fee and accruing interest. Of the full restitution amount owed, at
ieast $182,760.58 was jointly obtained with co-conspirator Antwaun Johnson. The
final amount of restitution and all specific recipients will be determined by the Court
at the time of sentencing.
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8. Guidelines Sentence
Pursuant to Fed. R. Crim. P. I l(cXl)(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 Uaited States
Sentencing Guidelines, as adjusted by any deparnrre 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. Acceptance of Responsibility - Three Levels
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 acceptance 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 16 or greater, and if the defendant complies
with the provisions of USSG $ 3E1.1(b) and all teffns of this Plea Agreement,
including but not limited to, the timely submission of the financial affidavit
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referenced in Paragraph 8.5., the United States agrees to file a motion pursuant to
USSG $ 3El.l(b) for a downward adjustment of one additional 1evel. The defendant
understands that the determination as to whether the defendant has qualified for a
downward adjustment of a third level for acceptance of responsibility rests solely
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 appeai, collateral attack, or otherwise.
10. Cooperation - Substantial Assistance to be Considered
Defendant agrees to cooperate fully with the united States in the
investigatioa and prosecution of other persons, and to testify, subjea 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 fuither include a fulland 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 government agrees to consider whether such cooperation
qualifies as "substantial assistance" in accordance with the poliry of the United States
Attorney for the Middle District of Florida, warranting the filing of a motion at the
time of sentencing recommending (1) a downward departure from the applicable
guideline range purcuant to USSG $5K1.1, or (2) the imposition of a sentence below
a statutory minimum, if any, pursuant to l8 U.S.C. $ 3553(e), or (3) both. If the
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cooperatiou is completed subsequent to sentencing, the govemment agrees to
consider whether such cooperation qualifies as "substantial assistance" in accordance
with the po1iry of the United States Attorney for the Middle District of Florida,
warranting 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
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.
11. Use of Information - Section 181.8
Pursuant to USSG $1B1.8(a), the United States agrees that no self-
incriminatiag 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 $181.8(b).
12. Cooperation - Responsibilities of Padies
a. The government 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
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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 untruthful testimony, statements, or information pursuant to this
agreement, or should the defendant falsely implicate or incriminate any person, or
should the defendant fail to voluntarily and umeservedly 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 any, committed while testifoing pursuant to this agreement, or for
obstruction ofjustice.
(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 of or refile such charges and prosecute the defeadant 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 ia the instant case, and being further
aware of defendant's rights, as to all felony charges pending in such cases (those
offemes 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 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
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agree to reinstatement of such charges by recision of any 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,
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 prosecure 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
starute of limitations and any speedy trial claims as to any such offenses.
(4) The government 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 furnished in the course of the
defendant's cooperation with the government.
(5) The defendant will not be permitted to wirhdraw rhe 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 alternative , at the option of the United States, the United States may
move the Court to declare this entire plea agreement null and void.
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13. Forfeirure 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 forfeirure,
pursuant to 18 U.S.C. g 981(a)(1)(C) aad 28 u.S.C. g 2461(c), 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 $187,300 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 jointly obtained
$159,900 in fraud proceeds with co-defendant Antwaun Johnson. Therefore, the
defendant and Antwaun Johnson will both be liable for the $159,900. The defendant
will be individually liable for the remaining $27,400. 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 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
property of the defendant (substitute assets), up to the amount of proceeds 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
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Program. The defendant agrees that forfeiture of substirute assets as authorized
herein shall not be deemed an alteration of the defeadant,s sentence.
The defendant additionally agrees 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 forfeirure should
authorize the United States Attorney's Oflice to conduct discovery (including
depositions, interrogatories, requests for production of documents, and the issuance
of subpoenas), pursuant to Rule 32.2(bX3) of the Federal Rules of Criminal
Procedure, to help ideatiff, locate, and forfeit substitute assets.
The defendant also agrees to waive all consdrutional, statutory, and
procedural challenges (including direct appeal, habeas co{pus, 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
Factual Basis below provides a sufficient factual and statutory basis for the forfeiture
of the property sought by the government. Pursuant ro Rule 32.2(b)(4), the
defendaat agrees that the preliminary order of forfeirure will satisfu the notice
requirement and will be final as to the defendant at the time it is entered. In the
event the forfeirure is omitted from the judgment, the defendant agrees that the
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forfeiture order may be incorporated into the written judgment at any time pursuant
to Rule 36.
The defendant agrees to take all steps tecessary to identifu and locate
all substitute assets and to transfer custody of such 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 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 any records of assets owned by the
defendant, and to consent to the release of &e defendant's tax returns for the
previous five years. The defendant agrees to be interviewed by the government, prior
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 Rute of Criminal Procedure 11 and USSG
$ lBl.8
will not proted 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 fulIand complete information about substitute
assets, these steps include, but are not limited to, the surrender of title, the signing of
a consent decree of forfeirure, and signing of any other documents necessary to
effectuate such transfers.
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Forfeiture of the defendant's assets shall not be treated as satisfaction of
any fine, restitution, cost of imprisonment, or any other penalty the Court may
impose upon the defendant in addition to forfeirure.
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 enhancemelt.
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
agreement. The forfeitability of any particular properry pursuant to this agreement
shall be determined as if the defendant had zurvived, and that determination shall be
binding upon defendant's heirs, successors and assigns until the agreed forfeirure,
including the forfeiture of any substitute assets, is final.
B. Standard Terms and Conditions
L 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. $ 3663A(c)(l); and the Court may order the defendant to make restirution
to any viaim of the offense(s), pursuant to l8 U.S.C. S 3663, including restifution as
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to all counts charged, whether or not the defendant enters a plea of guilry 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 restitution (28 U.S.C.
S 3003(bX2)), including, but not limited to, garnishment and execution, pursuant ro
the Maadatory Victims Restitution Act, in order to ensure that the defendant's
restifution obligation is satisfied".
On each count to which a plea of guilty is entered, the Court shall
impose a special assessment pursuant to I8 U.S.C. $ 3013. The special assessment is
due on the date of sentencing.
The defendant understands that this agreement imposes no limitation as
to fine.
2. Supervised Release
The defendant understands that the offense to which the defendant is
pleading provides for imposition of a 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. Immigration Consequences of Pleading Guilty
The defeadant 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.
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4. Sentencing Information
The United States reserves its right and obligation to report to the Court
and the United States Probation Office all informarion conceming the background,
character, and coaduct of the defendaat, to provide relevant factual information,
including the totaliry of the defendant's criminal 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 of this case, subject to any limitations set fofih
herein, if any.
5. Financial Disclosures
Pursuant to 18 u.s.c. s 36e(dx3) and Fed. R. Crim. p. 32(dX2XAXii),
the defendant agrees to complete and submit to the United States Attorney's Offrce
within 30 days of execution of this agreement an affrdavit 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 hetd 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 of assets 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
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years. The defendant similarly agrees and authorizes the United States Attorney's
Oflice to provide to, and obtain from, the United States Probation Office, the
financial affidavit, any of the defendant's federal, state, and local tax returns, bank
records and any other financial information concerning 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 deftadant
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.
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 oppoltunity 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 recommetdations and
present arguments to the Court, the sentence wil1be determined solely by the Court,
with the assistance of the United States Probation Office. Defendant further
understaads and acknowledges that any discussions between defendant or
defendant's attorney and the auomey or other agents for the govemment regarding
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 govemment
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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 Right to Appeal the Sentence
The defendant agrees that this Court has jurisdiction and authority to
impose any sentence up to the statutory maximum and expressly waives the right to
appeal defendant's sentence or any ground, including the ground that the Court
erred in determining the applicable guidelines range pursuaat to the United States
Sentencing Guidelines, except (a) the ground that the sentence exceeds the
defendant's applicable guidelines range as determined by &e 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. g 3742(b), then
the defendant is released from his waiver and may appeal the sentence as authorized
by 18 U.S.C. 5 37a2@)
8. Middle District of Florida Agreement
It is further understood that this agreement is limited to the Offlice of the
United States Attorney 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 aay, to the attention of other prosecuting officers or
others, if requested.
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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 guilry pursuant hereto.
10. Yoluntariness
The defendant acknowledges that defendant is entering into this
agreement and is pleading guilty freely and voluntarily without reliance upon any
discussions between the attorney for the government and the defendant and
defendant's attorney and without promise of benefit of any kind (other than tke
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 defendant's
undersigned couosel (if any). T?re 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 agaiast
compulsory seltincrimination, and the right to compulsory process for the
attendance of witnesses to tesdfy in defendant's defense; but, by pleading guitty,
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
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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 of counsel (if
any), defendant's answers may later be used against defendant in a prosecution for
perjury or lalse 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 serve on a jury, or to have possession of firearms.
11. Factual Basis
Defendant is pleading guilty because defendant is in fact guilry. The
defendant certifies that defendant does hereby admir that the facts set forth below are
true, and were this case to go to tria1, 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 of the United States government that provided support to
entrepreneurs and small businesses. The SBA enabled and provided for loans
through banks, credit unions, and other lenders. These loans had government-backed
guarantees. In addition to traditional SBA funding programs, the CARES Act, which
was signed into law in March 2020, established several new temporary programs and
provided for the expansion of others to address a Presidentially declared disaster, the
COVID-19 outbreak.
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One govemment response to the COYID-l9 outbreak was an expansion
of an existing disaster-related program-the Economic Injury Disaster Loan
(ElDLFto provide for loan assistance for small businesses and other eligible enrities
for loans up to $2 million. The EIDL proceeds could be used to pay certain
qualiffing expenses (i.e., fixed debts, payroll, accounts payable, and other bills) that
could have been paid had the disaster not occurred.
EIDL funds were issued directly from the United States Treasury, and
applicants applied through the SBA via an online portal and application. The EIDL
application process collected information concerning the business and the business
owner. Applicants electronically ce*ified that the information provided was accurate
and were warned that any false statement or misrepresentation to the SBA or any
misapplication of loan proceeds may result in sanctions, including criminal penalties.
All EIDL loan and advance disbursements were initiated by the SBA
Denver Finance Center located in Denver, Colorado which transmitted the payment
information through the Financial Management System (FMS) to the Treasury. The
primary seryer for FMS was in Sterling, Virginia.
Beginning as early as in or around April 2A20, and continuing through
at least in or around June 2021, in the Middle District of Florida and eisewhere, the
defendants Sherell Breus, Jessica Sejour, Antwaun Johnson, and others did
knowingly and wi1lfully combine, conspire, confederate, and agree with each other
and others, to commit wire fraud. The purpose of the illegal scheme was to use false
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and frauduleirt information to obtain loaas from federal government programs to
which the conspirators were not entitled. .- ----t
gtr Ail^L L,)
For instance, in July 2020 Sejo,ur wi@submi*ed two
false and fraudulent EIDL applications. The first application was zubmitted on July
| , 2A2A, for a business called Above and Beyond Transport LLC. This application
falsely daimed Above and Beyond was an operational business with l0 employees
and gross revfnues of $659,000 with $240,000 in costs of goods sold. In support of
her application, Sejour provided a fraudulently edited first page of a 2019 Form 1M0
U.S" Individual Tax Rerurn.
As a result of the material misinformation contained on the EmL
application, the SBA trarrsmitted two interstate wire fransfers. The first was an EIDL
Advance rransmitted on July 6,2A20 for $10,000, and the second v/as the EIDL
transmiRed on July 21,2A20 for $149,900. Bsth funds were deposited into a
Financial Institution #4 account ending inZl23. Sejour and co-conspirator Johnson
were the only authorized signers on this accocnt. Days after the funds rvere
deposited, Sejour and Johson sent a series of checks to Breus. In total, Sejour aod
Johson kicked back $35,264 of their fraudulently obtained funds to Breus. The
remaining funds were spent on personal items by Sejour and Johnson.
On July 7,2020,just one day afier receiving her EIDL Advance for
Above and Beyond, Sejour submitted her second EIDL application this time fsr a
cleaning service business. This application &lsely claimed her business had l0
employees with $77,000 in gross revenue and $22,000 in costs of goods sold. As a
Defendant's Initials E- 20
Case 8:25-cr-00516-WFJ-CPT Document 193 Filed 08/19/26 Page 21 of 22 PageID
475
result of the material misinformation contained in her application, on August
4,
2020, the SBA ffansmiffed one iastate wire payment in the amoun t of
$27,4*0. This
payment originated from outside Florida and was deposited into a Financial
Institution #4 account ending in 1686 located in the Middle District of Florida.
Sejour was the only authorized signer on this bank account. Contrary to the terms
of
her loan agreement, sejour also spent these funds on personal items.
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, persons involved, or other information
relating to this case.
12, Entire Agreement
This plea agreement constirutes the entire agreement between the
govemment and the defendant with respect to the aforementioned guilty plea and no
other promises, agreements, or representations exist or have been made to the
defendant or defendant's attorney with regard to such guilty plea.
Defendant's Initials .IS 2t
Case 8:25-cr-00516-WFJ-CPT Document 193 Filed 08/19/26 Page 22 of 22 PageID
476
13. Certification
The defendant and defendant's counsel certifu that this plea agreemenr
has been read in its entirety by (or has been read to) the deftndant and that defendant
fu1ly understands its terms.
DATED rhis l9m-. dav of Fntgusf , 2A26.
GREGORY W. KEHOE
United States Attorney
A. Sejour
Defendant United
Michael R. Kenneth
for Defendant Assistant United States Attorney
O5)7nto Chie( Economic Crimes Section
22
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