Plea Agreement — USA v. Erhinmwinrose et al (Dkt. 75, D. Colo.)

Summary

A Plea Agreement and Statement of Facts Relevant to Sentencing in United States of America v. Victor Henshaw Tobore a/k/a David Badru, Criminal Case No. 23-cr-00300-CNS-2, in the U.S. District Court for the District of Colorado, filed January 10, 2024 as Document 75; defense counsel is Rick Kornfeld. The defendant agrees to plead guilty to count 2 of the Indictment, conspiracy to commit money laundering under 18 U.S.C. § 1956(h), to pay restitution in an amount to be determined at sentencing and not to contest forfeiture. The stipulated facts state that the Fraud Ring obtained more than $8,119,037 from government programs, including $2,332,600 in EIDL and $5,704,967 in PPP losses. They describe Tobore as one of multiple runners who converted proceeds to cash and money orders. The government agrees to recommend imprisonment not greater than the low end of the guideline range.

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