United States v. Dennis Kinchen — Plea Agreement, Southern District of Georgia (Document 100)

Summary

A plea agreement in United States of America v. Dennis Kinchen, Case No. 4:22-cr-114 (Case 4:22-cr-00114-JRH-CLR), in the U.S. District Court for the Southern District of Georgia, filed January 24, 2023 as Document 100. Kinchen agrees to plead guilty to the lesser-included offense in Count 1, drug conspiracy under 21 U.S.C. § 846, and to Count 11, money laundering conspiracy under 18 U.S.C. §1956(h). The factual basis describes drug trafficking and states that on or about September 21, 2021 the SBA deposited $412,700 into an Infinity Trucking Company, LLC account, that $325,000 was then wired out for "Purchase Property," and that the government believes a residential property was bought with money traceable to misuse of SBA COVID EIDL loan funds. Count 1 carries a mandatory minimum of 5 years, and Kinchen consents to forfeiture of the Atlanta Condo.

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

Full text

Case 4:22-cr-00114-JRH-CLR         Document 100       Filed 01/24/23    Page 1 of 17




                     UNITED STATES DISTRICT COURT
                     SOUTHERN DISTRICT OF GEORGIA
                          SAVANNAH DMQION

UNITED STATES OF AMERICA                  )
                                          )
v.                                        )      Case No. 4:22-cr-114
                                          )
DENNIS KINCHEN                            )

                               PLEA AGREEMENT

       Defendant Dennis Kinchen, represented by his counsel, Skye Musson, Esq.,

and the United States of America, represented by Assistant United States Attorney

Marcela C. Mateo, respectfully state to this Honorable Court that they have reached

a plea agreement in this case. The terms and conditions of that agreement are as

follows:

1.     GUILTY PLEA

       Defendant agrees to enter a plea of guilty to the lesser-included offense

contained in Count 1 of the Indictment, which charges a violation of 21 U.S.C. § 846,

and to Count 11 of the Indictment, which charges a violation of 18 U.S.C. §1956(h).

2.     ELEMENTS AND FACTUAL BASIS

       The elem.ants necessary to prove the lesser-included of Count 1 are; (1) that

two or more people in some way agreed to try to accomplish a shared and unlawful

plan to possess 500 grams or more of a mixture or substance containing a detectable

amount of cocaine, a Schedule II controlled substance, a mixture or substance

containing a detectable amount of methamphetamine, a Schedule II controlled

substance, a mixture or substance containing a detectable amount of heroin, a



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Schedule I controlled substance, a mixture or substance containing a detectable

amount of marijuana, a Schedule I controlled substance; (2) that the Defendant knew

the unlawful purpose of the plan and willfully joined in it; and (3) that the object of

the unlawful plan was to possess with the intent to distribute and distribute the

controlled substance.

      The elements necessary to prove Count 11 are: (1) that two or more people

some way agree to try and accomplish a shared and unlawful plan to engage in money

laundering; and (2) the Defendant knew about the plan's unlawful purpose and

voluntarily joined it.

      Defendant agrees that he is, in fact, guilty of these offenses. Defendant admits

that the Government could prove each and every element of the offenses to which he

is pleading guilty. He agrees to the accuracy of the following facts, which satisfy each

of the offenses' required elements:

      Beginning on a date at least as early as April 2019, up to and including the

return date of this indictment, the precise dates being unknown, in Chatham,

Laurens counties, within the Southern District of Georgia, and elsewhere,             the

Defendant, DENNIS KINCHEN, aided and abetted by the co-defendants and others

known and unknown, did knowingly and intentionally agree with one or more people

to accomplish a shared and unlawful plan to possesses with intent to distribute 500

grams or more of a mixture or substance containing a detectable amount of cocaine,

a Schedule II controlled substance, a mixture or substance containing a detectable

amount of methamphetamine, a Schedule II controlled substance, a mixture or

substance containing a detectable amount of heroin, a Schedule I controlled

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substance, a mixture or substance containing a detectable amount of marijuana, a

Schedule I controlled substance. All in violation of Title 21, United States Code,

Sections 841(a)(l) and 846 and Title 18, United States Code, Section 2.
      Beginning as early as April 2019, law enforcement was investigating the drug

trafficking activities of DENNIS KINCHEN and others in the Southern District of

Georgia. The investigation revealed that KINCHEN was the source of supply for the

drug trafficking organization and distributed cocaine, heroin, methamphetamine and

marijuana to co-defendants and others.

      KINCHEN communicated with multiple co-conspirators on interception phone

lines about trucking business and then about narcotics distribution. KINCHEN

speaks to his source of supply in September 2020, which would later be identified as

AMARAL and trips would then be tracked and monitored to Hollywood, Florida,

through active interception on multiple phone lines.

      A search warrant was executed on KINCHEN's residence resulted in the

seizure of multiple kilos of cocaine, grams of heroin and pounds of marijuana.

      A search warrant executed on a residence associated with KINCHEN on

January 29, 2022, in Chatham County, resulted in the seizure of three firearms,

cocaine, heroin, and methamphetamine.

         Further, on or about September 21, 2021, in the Southern District of

Georgia, and elsewhere, the Defendant, DENNIS RODRIGUEZ KINCHEN, aided

and abetted by each other and by others known and unknown, with some joining the

conspiracy earlier and others joining later, did knowingly and intentionally combine,

conspire, confederate and agree with each other and others, to conduct and attempt

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to conduct financial transactions affecting interstate commerce, with funds which

were proceeds of a specified unlawful activity, that is conspiracy to commit wire fraud,

in violation of Title 18, United States Code, Section 1341.
      In furtherance of the conspiracy, the defendant committed and caused to be

committed in the Southern District of Georgia and elsewhere, financial transactions

affecting interstate commerce, using funds which were, and which the defendant

knew to be, proceeds of the unlawful conspiracy to commit wire fraud, through the

transactions limited below:

             a.     On or about September 21, 2021, the SBA deposited $412,700 into

Morris Bank account number 94595, held in the name of INFINITY TRUCKING

COMPANY, LLC.

             b.     Prior to receiving the $412,700 in SBA funds the statement

balance of Morris Bank account #94595 was only $4, 722.68.

             c.     Following this deposit, on October 21, 2021, the defendant

conducted a wire transfer in the amount of $325,000 from Morris Bank account #94595

to Colony Bank account number #8218 held in the name INFINITY TRUCKING CO

LLC. Documentation for this wire transfer stated that the purpose for the transfer

is "Purchase Property."

             d.     Prior to the receipt of this wire transfer, bank records indicated

account number #8218 had a balance of only $3,905.53. Following this, on October

22, 2021, the records show an outgoing wire transfer to a law firm in the amount of

$25,000.



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             e.     On October 25, 2021, a Colony Bank "Miscellaneous Form" was

utilized to conduct a transfer in the amount of $300,000. On the form a handwritten

note readB, "tranBfer to cd #213026794 loan collateral per Dennis Kinchen." This
"Miscellaneous Form" also purports to be signed by KINCHEN.

             f.     On this same date, October 25, 2021, KINCHEN was also issued a

check from Colony Bank for the amount of $300,000. The back of this check shows

that it was specially endorsed by KINCHEN in the following manner: "Pay to the

order of Infinity Trucking Co LLC." The bank's internal transaction stamps show,

however, that this check was not deposited into Colony Bank account number #8218

until October 26, 2021; after the purchase of the CD on October 25, 2021.

Furthermore, these Colony Bank records included a separate ''Miscellaneous Form,"

which is also dated October 25, 2021, which included the handwritten description "loan

fees xx8692 (POC)" and which also purports to be signed by KINCHEN.

             g.     These records corroborate the belief that the funds used to

purchase CD #213026794 were the SBA funds that KINCHEN transferred from his

account at Morris Bank (account #94595).

             h.     Additionally, on November 3, 2021, a cash deposit in the

amount of $6,500 was made into Colony Bank account #8218. The next day, on

November 4, 2021, Colony Bank records detail an outgoing wire transfer to another

law firm in the amount of $306,380.72.

             1.    An internet search of the above referenced law firm shows that they

are located in the Atlanta, Georgia area, and specializes in only four areas, including

residential real estate closings. A search of the Fulton County, Georgia's Board of

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Assessors website revealed a property record in the name of Dennis KINCHEN

for property located at 2734 Peachtree Rd NW, Unit #C202. The property record

further shows that the sale to KINCHEN took place on November 5, 2021.
             j.    The Government believes that this residential property was

purchased with money traceable to and/or derived from Wire Fraud and subsequent

misuse of SBA COVID EIDL loan funds as well as through the use of comingled illicit

proceeds.

      All done in violation of Title 18, United States Code, Section 1956(h).

3.    POSSIBLE SENTENCE

      Defendant's guilty plea to the lesser offense of Count 1 will subject him to the

following maximum possible sentence: Imprisonment of not more than 40 years, a

supervised release term of at least 4 years, and a $5,000,000 fine. Defendant's guilty

plea will subject him to a mandatory minimum of 5 years imprisonment.

      Defendant's guilty plea to Count 11 will subject him to the following maximum

possible sentence: Imprisonment of not more than 20 years; a fine of not more than

$500,000 or twice the value of the property involved in the transaction, whichever is

greater; and a supervised release term of not more than 3 years. The Court

additionally must impose a $100 special assessment as to each count.

4.    NO PROMISED SENTENCE

      No one has promised Defendant that the Court will impose any particular

sentence or a sentence within any particular range. The Court is not bound by any

estimate of sentence given or recommendations made by Defendant's counsel, the

Government, the U.S. Probation Office, or anyone else. The Court may impose a


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sentence up to the statutory maximum. Defendant will not be allowed to withdraw

his plea of guilty if he receives a more severe sentence than he expects.

5.       COURT'S USE OF GUIDELINES
         The Court is obligated to use the United States Sentencing Guidelines to

calculate the applicable guideline range for Defendant's offense and to consider that

range, possible departures under the Sentencing Guidelines, and other sentencing

factors under 18 U.S.C. § 3553(a), in determining his sentence. The Sentencing

Guidelines are advisory; the Court is not required to impose a sentence within the

range those Guidelines suggest. The Sentencing Guidelines are based on all of

Defendant's relevant conduct, pursuant to U.S.S.G. § lBl.3, not just the facts

underlying the particular Count to which Defendant is pleading guilty.

6.       AGREEMENTS REGARDING SENTENCING GUIDELINES

         a.    Acceptance of Responsibility

         If the Court determines that Defendant qualifies for an adjustment under

U.S.S.G. § 3El.l(a), and the offense level prior to operation of§ 3El.l(a) is 16 or

greater, the government will move for an additional one-level reduction in offense

level pursuant to Section 3El.l(b) based on Defendant's timely notification of the

Defendant's intention to enter a guilty plea.

         b.    Use of Information

         The Government is free to provide full and accurate information to the Court

and U.S. Probation Office for use in calculating the applicable Sentencing Guidelines

range.



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      c.     Quantity of Drugs

      The Government and Defendant agree to recommend to the U.S. Probation

Office and the Court at sentencing that, for purposes of Section 2D 1.1 of the

Sentencing Guidelines, the offense involved at least 3,000 kilograms but less 10,000

kilograms of converted drug weight.

      d.     Specific Offense Characteristics

      The Government and Defendant agree that a factual basis exists to support a

specific offense characteristic that a dangerous weapon, specifically a firearm, was

possessed as part of the drug-trafficking crime pursuant to U.S.S.G. §2D1.1. Thus, a

2 level enhancement is applicable.

7.     COOPERATION

      a.     Complete and Truthful Cooperation

      If the Defendant chooses to cooperate, the Defendant understands that he must

provide full, complete, candid, and truthful cooperation in the investigation and

prosecution of the offenses charged in Defendant's Indictment and any related

offenses. Defendant shall fully and truthfully disclose Defendant's knowledge of

those offenses and shall fully and truthfully answer any question put to him by law

enforcement officers about those offenses.

      This agreement does not require Defendant to "make a case" against any

particular person. Defendant's benefits under this agreement are conditioned only

on Defendant's cooperation and truthfulness, not on the outcome of any trial, grand

jury, or other proceeding.




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       b.     Motion for Reduction in Sentence Based on Cooperation

      The Government, in its sole discretion, will decide whether Defendant's

cooperation qualifies as "substantial assistance" pursuant to U.S.S.G. § 5Kl.1 or Fed.
R. Crim. P. 35 and thereby warrants the filing of a motion for downward departure

or reduction in Defendant's sentence. If such a motion is filed, the Court, in its sole

discretion, will decide whether, and to what extent, Defendant's sentence should be

reduced. The Court is not required to accept any recommendation by the government

that the Defendant's sentence be reduced.

8.     FINANCIAL OBLIGATIONS AND AGREEMENTS

      a.     Special Assessment

      Defendant agrees to pay a special assessment in the amount of $100.00 per

count, payable to the Clerk of the United States District Court, which shall be due

immediately at the time of sentencing.

      b.     Required Financial Disclosures

      Not later than 30 days after the Defendant enters a guilty plea, Defendant

shall complete a financial disclosure form listing all his assets and financial interests,

whether held directly or indirectly, solely or jointly, in his name or in the name of

another. Defendant shall sign the financial disclosure form under penalty of perjury

and provide that form to the Financial Litigation Unit of the United States Attorney's

Office and to the United States Probation Office. Defendant authorizes the United

States to obtain credit reports on Defendant and to share the contents of those reports

with the Court and the United States Probation Office. Defendant also authorizes



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the United States Attorney's Office to inspect and copy all financial documents and

information held by the United States Probation Office.

        c.    Financial Examination
        Defendant will submit to an examination under oath on the issue of his

financial disclosures and assets if deemed necessary by the United States. Such

examination will occur not later than 30 days after the entry of Defendant's guilty

plea.

        d.    For/eiture

        The Defendant acknowledges that he obtained and/or acquired property that

is subject to forfeiture as a result of his violations of the offenses charged in Counts 1

and 11 of the above-captioned Indictment, as well as his violations of 18 U.S.C.

§§ 1341 and 1343. The Defendant consents to the forfeiture of all right, title and

interest in the real property located at 2734 Peachtree Rd NW, Unit #C202, Atlanta,

GA 30305 (the "Atlanta Condo"), pursuant to 18 U.S.C. § 981(a)(l)(A), as real property

involved in a transaction or attempted transaction in violation of section 18 U.S.C. §

1956; and/or, pursuant to 18 U.S.C. § 981(a)(l)(C) and 28 U.S.C. § 2461(c). as

property, real or personal, constituting, or derived from, proceeds obtained directly

or indirectly as a result of violations of 18 U.S.C. §§ 1341 and 1343, and/or as

substitute assets, pursuant to 21 U.S.C. § 853(p). The Defendant consents to the

entry of a Preliminary Order of Forfeiture, pursuant to Rule 32.2 of the Federal Rules

of Criminal Procedure, forfeiting the Atlanta Condo. Further, the defendant consents

to the forfeiture of the Atlanta Condo in the civil forfeiture action (the "Civil



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Forfeiture Action'/, United States v. 2734 Peachtree Rd NW, Unit #C202 Atlanta, GA

30305, 4:22-cv-00064-JRH-CLR (S.D.Ga.).

      The Defendant admits to each of the allegations set forth in the Verified

Complaint in the Civil Forfeiture Action, Dckt. No. 1. Further, the Defendant agrees

to fully assist the Government in effectuating the surrender and forfeiture of the

Atlanta Condo in the Civil Forfeiture Action, and to take whatever steps are

necessary to ensure that clear title passes to the United States, including by

providing any information and/or evidence upon request of the government, including

testimony and any documentary evidence. The Defendant agrees not to file a claim

or petition seeking remission or contesting the forfeiture of the Atlanta Condo in any

administrative or judicial (civil or criminal) proceeding, including the Civil Forfeiture

Action, and further agrees not to assist any person or entity in the filing of any claim

or petition seeking remission or contesting the forfeiture of the Atlanta Condo in any

administrative or judicial (civil or criminal) forfeiture proceeding, including the Civil

Forfeiture Action. Further, if any third party files a claim to the Atlanta Condo,

including any claim in the Civil Forfeiture Action, the defendant will assist the

government in defending such claim. The Defendant also waives all statutory

deadlines to the forfeiture, including but not limited to deadlines set forth in 18

u.s.c. § 983.
      The failure of the Defendant to forfeit any monies and/or properties as required

under this agreement and to assist the government with the forfeiture of the Atlanta

Condo, including the failure of the Defendant to providing any information and/or

evidence as outlined above, may constitute a material breach of this agreement. Upon

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such a breach, the defendant will not be entitled to withdraw the plea, but the Office

may bring additional criminal charges against the defendant.

       The Defendant knowingly and voluntarily waives his right to any required

notice concerning the forfeiture of any monies and/or properties forfeited hereunder,

including notice set forth in an indictment, information, civil complaint or

administrative notice. In addition, the Defendant knowingly and voluntarily waives

his right, if any, to a jury trial on the forfeiture of the Atlanta Condo, and waives all

constitutional, legal and equitable defenses to the forfeiture of said monies and/or

properties, including, but not limited to, any defenses based on principles of double

jeopardy, the Ex Post Facto clause of the Constitution, any applicable statute of

limitations, venue, or any defense under the Eighth Amendment, including a claim

of excessive fines.

       The Defendant agrees that the forfeiture of the Atlanta Condo is not to be

considered a payment of a fine, penalty, restitution loss amount, or any income taxes

that may be due, and shall survive bankruptcy.

       e.     No Transfer of Assets

      Defendant certifies that he has made no transfer of assets in contemplations

of this prosecution for the purpose of evading or defeating financial obligations [or

forfeiture] created by this Agreement or that may be imposed upon him by the Court

at sentencing. Defendant promises that he will make no such transfers in the future .

      f.     Material Change in Circumstances

      Defendant agrees to notify the United States of any material change in

circumstances, as described in 18 U.S.C. § 3664(k), that occurs prior to sentencing in


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this case. Such notification will be made within seven (7) days of the event giving

rise to the changed circumstances, and in no event later than the date of sentencing.

         g.    Enforcement
         Any payment schedule imposed by the Court is without prejudice to the United

States to take all actions and remedies available to it to collect the full amount of the

financial obligations imposed by the judgment of the Court in this case. Defendant

understands and agrees that the financial obligations [and forfeiture] imposed by the

judgment of the Court in this case will be placed on the Treasury Offset Program so

that any federal payment that Defendant receives may be offset and applied to the

judgment debt without regard to or affecting any payment schedule imposed by the

Court.

9.       WAIVERS

         a.    Waiver of Appeal

         Defendant entirely waives Defendant's right to a direct appeal of Defendant's

conviction and sentence on any ground (including any argument that the statute to

which the Defendant is pleading guilty is unconstitutional or that the admitted

conduct does not fall within the scope of the statute). The only exceptions are that

the Defendant may file a direct appeal of Defendant's sentence if (1) the court enters

a sentence above the statutory maximum, (2) the court enters a sentence above the

advisory Sentencing Guidelines range found to apply by the court at sentencing; or

(3) the Government appeals the sentence.         Absent those exceptions, Defendant

explicitly and irrevocably instructs Defendant's attorney not to file an appeal.



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      b.      Waiver of Collateral Attack

       Defendant entirely waives Defendant's right to collaterally attack Defendant's

conviction and sentence on any ground and by any method, including but not limited
to a 28 U.S.C. § 2255 motion. The only exception is that Defendant may collaterally

attack Defendant's conviction and sentence based on a claim of ineffective assistance

of counsel.

       c.     FOIA. and Privacy Act Waiver

       Defendant waives all rights, whether asserted directly or through a

representative, to request or receive from any department or agency of the United

States any record pertaining to the investigation or prosecution of this case under the

authority of the Freedom of Information Act, 5 U.S.C. § 552, or the Privacy Act of

1974, 5 U.S.C. § 552a, and all subsequent amendments thereto.

      d.      Fed. R. Crim. P. 11(/) and Fed. R. Evid. 410 Waiver

      Rule ll(f) of the Federal Rules of Criminal Procedure and Rule 410 of the

Federal Rules of Evidence ordinarily limit the admissibility of statements made by a

defendant during the course of plea discussions or plea proceedings. Defendant

knowingly and voluntarily waives the protections of these rules. If Defendant fails

to plead guilty, or his plea of guilty is later withdrawn, all of Defendant's statements

in connection with this plea, and any leads derived therefrom, shall be admissible for

any and all purposes.

10.   DEFENDANT'S RIGHTS

      Defendant has the right to be represented by counsel, and if necessary have

the court appoint counsel, at trial and at every other critical stage of the proceeding.

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Defendant possesses a number of rights which he will waive by pleading guilty,

including: the right to plead not guilty, or having already so pleaded, to persist in

that plea; the right to a jury trial; and the right at trial to confront and cross-examine

adverse witnesses, to be protected from compelled self-incrimination, to testify and

present evidence, and to compel the attendance of witnesses.

11.   SATISFACTION WITH COUNSEL

      Defendant has had the benefit of legal counsel in negotiating this agreement.

Defendant believes that his attorney has represented him faithfully, skillfully, and

diligently, and he is completely satisfied with the legal advice given and the work

performed by his attorney.

12.   BREACH OF PLEA AGREEMENT

      Defendant breaches this agreement if, prior to sentencing in his case, he fails

to comply with any of the terms of this agreement, withdraws or attempts to

withdraw his guilty plea, refuses to accept responsibility for his criminal conduct,

obstructs justice by tampering with witnesses or evidence, or commits any new

crimes. If Defendant breaches the plea agreement, the government is .r eleased from

any agreement herein regarding the calculation of the advisory Sentencing

Guidelines or the appropriate sentence. In addition, the Government may:               (1)

declare the plea agreement null and void, (2) reinstate any counts that may have been

dismissed pursuant to the plea agreement, and/or (3) file new charges against

Defendant that might otherwise be barred by this plea agreement. Defendant waives

any statute-of-limitations or speedy trial defense to prosecutions reinstated or

commenced under this paragraph.

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 13.     ENTIRE AGREEMENT

         This agreement contains the entire agreement between the Government and

 Defendant. The Government has made no promises or representations except those

 set forth in writing in this Plea Agreement. The Government further denies the

 existence of any other terms or conditions not stated herein. No other promises,

 terms or conditions will be entered into unless they are in writing and signed by all

the parties.

                                        DAVID H. ESTES
                                        UNITED STATES ATTORNEY



Date                                  ~~ atr1c1a   .   o es




IDate.     ·   Wl. L                   M
                                       Assi, tant United States Attorney




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       I have read and carefully reviewed this agreement with my attorney.                I

understand each provision of this agreement, and I voluntarily agree to it. I hereby

stipulate that the factual basis set out therein is true and accurate in every respect.


\:>-,g-?a
Date
                                        D:e."'~ J ( ~
                                        Dennis Kinchen, Defendant


       I have fully explained to Defendant all of his rights, and I have carefully

reviewed each and every part of this agreement with him. I believe that he fully and

completely understands it, and that his decision to enter into this agreement is an

informed, intelligent, and voluntary one.



~f)//
Date




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